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1986 (8) TMI 86 - ITAT AHMEDABAD-CExtract: .......t sufficient to establish mens rea. The essence of mens rea is not the absence of outstanding honesty but the presence of positive dishonesty. The assessee cannot be punished for lacking in exemplary honesty. That is an ideal but not the expectation of penal law. Therefore, we uphold the order of the Commissioner (Appeals) and reject these appeals.
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