Determination of tax: stays and appellate pendency exclude limitation periods, with procedural safeguards and recovery on self-assessment. Periods of stay or appellate pendency are excluded from computing limitation for reassessment; where fraud or wilful suppression is not established, the ... Summary
Determination of tax: stays and appellate pendency exclude limitation periods, with procedural safeguards and recovery on self-assessment.
Periods of stay or appellate pendency are excluded from computing limitation for reassessment; where fraud or wilful suppression is not established, the proper officer shall determine tax under ordinary reassessment provisions. Appellate directions must be implemented within two years. A hearing must be granted on written request or where an adverse decision is contemplated; adjournments are limited and must be recorded. Orders must state facts and reasoning, demands cannot exceed notice grounds, and appellate modification of tax adjusts interest and penalty. Interest is payable on short-paid tax regardless of mention; self-assessed unpaid tax is recoverable under recovery provisions; duplicate penalties for the same act are barred.
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