Tax authority's substitution of projected figures with actuals overturned; original acquisition valuation upheld; transfer pricing issues remitted for...
Beneficial owner held liable for differential customs duty; royalties added under Rule 10(1)(c); confiscation, penalties under s.111(m), s.114A, s.112...
The AT dismissed the appeal, upholding provisional attachment orders and refusing interference. The Tribunal found a prima facie case of offence under Section 3 of the Act of 2002 and noted pending criminal proceedings against the appellants, precluding a finding of innocence; the 180-day termination calculation and exclusions were addressed against the appellants. The appellants failed to satisfactorily establish lawful source of attached assets: sale deeds were unregistered or unsupported, ancestral title and consideration documentation were inadequate, and claimed timber business records (firm registration, ledger accounts, invoices) were unreliable or handwritten and inconsistent with statements under Section 50(2)/(3). Relief from attachment was therefore denied and the appeals dismissed.
The AT dismissed the appeal, upholding provisional attachment orders and refusing interference. The Tribunal found a prima facie case of offence under Section 3 of the Act of 2002 and noted pending criminal proceedings against the appellants, precluding a finding of innocence; the 180-day termination calculation and exclusions were addressed against the appellants. The appellants failed to satisfactorily establish lawful source of attached assets: sale deeds were unregistered or unsupported, ancestral title and consideration documentation were inadequate, and claimed timber business records (firm registration, ledger accounts, invoices) were unreliable or handwritten and inconsistent with statements under Section 50(2)/(3). Relief from attachment was therefore denied and the appeals dismissed.
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