The court noted that the respondent’s persistent non-compliance constituted wilful disobedience, amounting to civil contempt under Section 2(b) of the Contempt of Courts Act.

Mere non-reflection of income in ST-3 returns, without establishing taxability, cannot be equated with deliberate suppression’ stated the appellate tribunal.

A nation’s right to tax income arising within its own country is an inherent sovereign power. Any application of filters or diffusers to this is a direct attack or threat to its sovereignty which can affect a Nation’s long-term interest