Voluntary disclosure reduces penalty exposure when made before audit notification, with staged relief and enhanced repeat-offence penalties. Section 87 sets conditional mitigation and cancellation mechanisms for penalties: penalties are cancelled if the taxable amount is wholly reduced; voluntary written disclosure to the Commissioner before or after audit notification yields staged reductions; reliance on a Commissioner determination or ruling negates penalty liability; prompt disclosure and payment during specified proceedings permits substantial reduction. The section also mandates escalated specified penalties for subsequent similar failures where prior penalties were assessed and not fully remitted after objection.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Voluntary disclosure reduces penalty exposure when made before audit notification, with staged relief and enhanced repeat-offence penalties.
Section 87 sets conditional mitigation and cancellation mechanisms for penalties: penalties are cancelled if the taxable amount is wholly reduced; voluntary written disclosure to the Commissioner before or after audit notification yields staged reductions; reliance on a Commissioner determination or ruling negates penalty liability; prompt disclosure and payment during specified proceedings permits substantial reduction. The section also mandates escalated specified penalties for subsequent similar failures where prior penalties were assessed and not fully remitted after objection.
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