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    <title>2010 (8) TMI 53 - CESTAT, NEW DELHI</title>
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    <description>Corroborated circumstantial evidence was sufficient to establish, on a preponderance of probability, that the appellants were the real persons controlling AJP and ST, despite the nominal proprietor&#039;s claim that he was only a front. The earlier statement implicating the appellants retained evidentiary value because it was later reaffirmed and not shown to have been taken under coercion. On that footing, the penal provisions were attracted against the appellants for their role in the clandestine operations, but the Tribunal found the original penalties excessive and reduced them while upholding liability in principle.</description>
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      <link>https://www.taxtmi.com/caselaws?id=78154</link>
      <description>Corroborated circumstantial evidence was sufficient to establish, on a preponderance of probability, that the appellants were the real persons controlling AJP and ST, despite the nominal proprietor&#039;s claim that he was only a front. The earlier statement implicating the appellants retained evidentiary value because it was later reaffirmed and not shown to have been taken under coercion. On that footing, the penal provisions were attracted against the appellants for their role in the clandestine operations, but the Tribunal found the original penalties excessive and reduced them while upholding liability in principle.</description>
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