Penal liability accrues per counterfeit-note transaction; aggregate Rs.5,40,000 demand unlawful, Rs.10,000 minimum; Section 12A penalty quashed over submitted report

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....The AT partly allowed the appeal by the appellant bank. The Tribunal held that penal liability under the relevant statutes accrues per transaction (each counterfeit-note disclosure) rather than per monthly reporting obligation, rendering the aggregate demand of Rs.5,40,000 (for 54 transactions) unlawful and noting the statutory minimum penalty of Rs.10,000 per transaction. Separately, the AT quashed the impugned Rs.200,000 penalty levied under Section 12A insofar as it related to the bank's alleged failure to furnish information, because the bank had furnished the requisite report by letter dated 26.12.2018 which the Director, FIU had ignored. The order below is modified accordingly.....