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of <h1>Stayed periods excluded from limitation; fraud-findings treated as non-fraud; adjudication deadlines, hearing rights, interest, no double penalties</h1> Where a judicial stay operates, the stayed period is excluded when computing limitation for reassessment; if an appellate body finds fraud or willful suppression unproved in a fraud-based notice, the officer must determine tax as if a non-fraud notice were issued. Adjudication orders must be issued within statutory timeframes or are deemed concluded; periods spent in appellate litigation that affect revenue are excluded from limitation. Affected persons are entitled to hearing and reasonable adjournments (not more than three), the officer must record facts and reasons, demands cannot exceed grounds or amounts in the notice, interest is payable irrespective of mention in the order, modifications by appeal adjust interest/penalty, self-assessed unpaid tax is recoverable under recovery provisions, and double penalties for the same act are prohibited.
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