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<h1>Wilful tax evasion: criminal penalties include rigorous imprisonment and fines for intentional under reporting or false records.</h1> Clause 478 establishes a criminal offence for a wilful attempt to evade tax, prescribing rigorous imprisonment and fines according to the scale of the evasion and preserving liability for penalties under the Act. It defines such wilful attempt to include possession or making of false entries in books or documents, wilful omission of relevant entries, and creating circumstances intended to enable tax evasion, while allowing court discretion to impose fines in specified cases.