In the result, the appeal of the assessee is Partly allowed
u/s 271AAB.\"\n(c) Issue of Mens rea:-\nThe appellant has also contended that in imposition of penalty mens-rea also\nplays a vital role before imposing the penalty, it is always compulsory to prove the\nmens-rea of the assessee as malafide for concealment of income or for\navoidance of any provision of law in force intentionally.\nThe above