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Amended Income Tax Act Section 281: Mens Rea Not Considered in Recovery; Assessee Must Prove Case in Civil Court.

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....Recovery proceedings - attachment of property - order u/s 281 of the Income Tax Act - under the amended provision, the question of mens rea or intention to defraud does not arise - it is up to the assessee under the amended provision, to go to the Civil Court and establish that his case falls under the proviso to section 281(1)....