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          Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.

          Provisions expressly mentioned in the judgment/order text.

          <h1>Minor breach protections prevent penalties for trivial, rectifiable tax errors and require opportunity to be heard.</h1> Section 126 precludes penalties for minor breaches - including small-amount tax discrepancies and documentation errors apparent on the record and easily rectifiable - absent fraud or gross negligence; requires penalties to be commensurate with the breach; mandates an opportunity to be heard and specification in the penalty order of the nature of the breach and applicable provision; treats voluntary pre-discovery disclosures as a mitigating factor; and excludes cases where penalties are fixed sums or fixed percentages.

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