Commissioner's discretion to reduce or waive minimum tax penalties when taxpayer voluntarily discloses and cooperates. The amendment grants the Commissioner discretion to reduce or waive the minimum penalty under clause (i) or clause (iii) where the taxpayer, before notice or detection, voluntarily and in good faith disclosed full particulars, cooperated with assessment enquiries, and has paid or arranged payment of tax or interest; Board approval is required if the aggregate minimum penalty exceeds a specified monetary threshold, and any order under this discretion is final and not open to challenge.
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.
Commissioner's discretion to reduce or waive minimum tax penalties when taxpayer voluntarily discloses and cooperates.
The amendment grants the Commissioner discretion to reduce or waive the minimum penalty under clause (i) or clause (iii) where the taxpayer, before notice or detection, voluntarily and in good faith disclosed full particulars, cooperated with assessment enquiries, and has paid or arranged payment of tax or interest; Board approval is required if the aggregate minimum penalty exceeds a specified monetary threshold, and any order under this discretion is final and not open to challenge.
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