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    <description>Goods intercepted in transit without the documents required under the relevant provision were treated by the authorities and Tribunal as attracting the statutory presumption of an attempt to evade tax. The later claim that the goods were intended for export supply was rejected as an afterthought, and the concurrent factual findings were upheld because no material was shown to have been ignored or any incorrect legal provision applied. On that basis, the view that the penalty provision applied was held to be a possible view on facts, and no perversity was demonstrated, so no substantial question of law arose.</description>
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