that no penalty on account of a human
error can be levied. The observations of the Hon'ble Supreme
Court read as under ... total income. This can only
be described as a human error which we are all prone
to make. The calibre and expertise of the assessee
deserves to be ignored having regard to possibility of human error, voluminous
nature of the inventory and estimations adopted by the department.
• The argument ... appellant is not acceptable as all the possible human error
had already been considered
• Thus, the arguments for difference
deserves to be ignored having regard to possibility of human error, voluminous
nature of the inventory and estimations adopted by the department.
• The argument ... appellant is not acceptable as all the possible human error
had already been considered
• Thus, the arguments for difference
genuine mistakes. The client code modifications permit brokers to
rectify human errors when a inadvertently provides a wrong code or when or a
wrong code ... genuine mistakes. The
client code modifications permit brokers to rectify human errors when a
inadvertently provides a wrong code or when or a wrong code
taxable
in the return of income. In view of this inadvertent human
error, vide letter dated 20/12/2019, the Appellant
voluntarily offered the receipts ... Appellant did
not have any intention to evade tax. The inadvertent
human error was corrected as soon as the same came to
the notice
getting back One carton
would not be cost effective."
- This human error is further corroborated by multiple objective
factors:
a. The items constitute merely ... Customs Act.
16. The appellant has corroborated his argument about the human error
with the factors like :
The items constitute merely 0.26% of the total
furnishing of inaccurate particulars without appreciating that it
was inadvertent human error.
ITA No. 109/M/2019 2
Illies Engg.
3. Briefly stated, the facts ... particulars, the
error incurred was a bonafide and an inadvertent human error, purely due to
oversight and completely unintentional.
The Ld. counsel also draws
Houston (USA) office
during investigation it was recorded that it was human error of Mr. Bob
Rushton which led to the offending import. Penalty ... notice. On this basis, it
was clarified that it was a human error and may be condoned. On 4.4.2012,
6|Page C/11010/2014
intention is not proved as it might be
occurred due to human error.
II. Further, it has been substantiated that from amongst the
Electric Loco ... deliberately and that the error in question was only a
human error and justified by the prevailing practice.
VI. The allegation of violation of guidelines
ADSPN7217K of Shri K.
Surendran Nair and that this is human error which should
be condoned. As noted earlier, the identity of a partnership
firm ... individual are separate and distinct;
and the argument of human error here does not hold good
particularly when the individual concerned is also engaged