Supreme Court on Tax Determination and Criminal Culpability

Ambey Constructech challenged the Punjab & Haryana HC judgment arising from a Section 276C prosecution. Before the Supreme Court, the assessee argued that the ₹15 crore receipt had admittedly been disclosed and that only the related expenses were disallowed, making it difficult to characterise the assessee as a wilful tax evader or wilful defaulter. 

The Supreme Court issued notice and, pending the proceedings, stayed further action on the complaint.