...and, in our opinion, no further finding is required that the assessee had also the mens rea. The statute does not contemplate that. Even otherwise, mens rea is a state of mind. Under the criminal law, mens rea is considered as the ‘guilty intention’, but when it is relatable to tax delinquency, which is a civil obligation, it implies a ‘blameworthy conduct’. Therefore, unlike in criminal cases, where...is essential for the prosecution to establish that the accused had a guilty intention or, in other words, the requisite mens rea before recording conviction, the obligation on the part of the Revenue, in cases of...party with in the ambit of that section. The application of the doctrine of mens rea in cases of tax delinquency has been nicely summed up in ‘Carpus Juris Secundum’, Volume 35, at page 580 in paragraph...