Vicarious liability for corporate tax offences extends to officers and partners, subject to a due diligence defence. Section 137 imposes vicarious liability for offences by a company on the company and those in charge at the time, and assigns personal liability to directors, managers, secretaries or officers where the offence occurred with their consent, connivance or negligence; the rule extends mutatis mutandis to firms, LLPs, HUFs and trusts, while preserving a defence for persons who prove lack of knowledge or that they exercised all due diligence to prevent the offence.