Delayed filing of SIMS and LMPC certificates was treated as a procedural import-compliance lapse because the certificates were eventually produced and the record did not show mala fide intent or intent to evade. On that basis, the redemption fine and penalty under section 112(a)(i) were moderated, with the fine reduced to Rs. 1,00,000 and the penalty reduced to Rs. 50,000. Penalty under section 114AA was set aside because that provision applies only to knowingly or intentionally false or incorrect documents or statements, and no evidence established such knowledge or intent.
Delayed filing of SIMS and LMPC certificates was treated as a procedural import-compliance lapse because the certificates were eventually produced and the record did not show mala fide intent or intent to evade. On that basis, the redemption fine and penalty under section 112(a)(i) were moderated, with the fine reduced to Rs. 1,00,000 and the penalty reduced to Rs. 50,000. Penalty under section 114AA was set aside because that provision applies only to knowingly or intentionally false or incorrect documents or statements, and no evidence established such knowledge or intent.
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