Commissioner Of Income Tax vs Kalyan Das Rastogi

Whether penalty proceedings under Section 271(1)(a) of the Income Tax Act require proof of mens rea (guilty mind) as they are quasi-criminal in nature --- Held No, following Gujarat Travancore Agency vs. CIT, penalty under Section 271(1)(a) is a civil obligation and does not require establishment of mens rea; the Tribunal's contrary view raises a question of law.