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Liability to pay fine and penalty - The Punjab & Haryana High Court allowed the appeal, quashing the impugned order. The Court emphasized the necessity of proving mens rea for imposing penalties under Section 11AC and ruled that proper reconciliation of records with valid invoices negated the presumption of intent to evade duty. The decision reaffirms the importance of adherence to procedural and evidentiary standards in the imposition of statutory penalties.