Repeated short payments trigger penalty when shortfalls occur across multiple returns within six consecutive tax periods. Three short payments in respect of three returns within any six consecutive tax periods constitute a repeated short payment for levy of penalty, operating as a mechanical trigger based on the number of returns showing short payment within the prescribed rolling window.
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Provisions expressly mentioned in the judgment/order text.
Repeated short payments trigger penalty when shortfalls occur across multiple returns within six consecutive tax periods.
Three short payments in respect of three returns within any six consecutive tax periods constitute a repeated short payment for levy of penalty, operating as a mechanical trigger based on the number of returns showing short payment within the prescribed rolling window.
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