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    <title>Section 122(1A) extends penalty to persons who benefited from and caused contravening transactions, even for earlier conduct.</title>
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    <description>Section 122(1A) is construed to cover &quot;any person&quot; other than the taxable person where that person retained the benefit of the contravening transactions and acted at whose instance they were done; on that basis, partners of a firm can be proceeded against if those factual conditions are recorded. The provision is treated as complementary to Section 122(1), not as creating a new independent offence, so it may apply to transactions predating 1 January 2021 if the show-cause notice was issued after the provision came into force. The writ challenge was rejected, while the petitioners were left free to contest the factual findings before the Appellate Tribunal.</description>
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      <title>Section 122(1A) extends penalty to persons who benefited from and caused contravening transactions, even for earlier conduct.</title>
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      <description>Section 122(1A) is construed to cover &quot;any person&quot; other than the taxable person where that person retained the benefit of the contravening transactions and acted at whose instance they were done; on that basis, partners of a firm can be proceeded against if those factual conditions are recorded. The provision is treated as complementary to Section 122(1), not as creating a new independent offence, so it may apply to transactions predating 1 January 2021 if the show-cause notice was issued after the provision came into force. The writ challenge was rejected, while the petitioners were left free to contest the factual findings before the Appellate Tribunal.</description>
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