Contesting adverse tax judgments on merits required for specified issue categories regardless of monetary thresholds or tax effect. Adverse tax decisions on specified categories must be contested on merits irrespective of monetary thresholds or absence of tax effect. The amended paragraph directs appeals in cases involving constitutional validity challenges; findings that a Board order, notification, instruction or circular is illegal or ultra vires; accepted Revenue Audit objections; additions for undisclosed foreign income/assets or foreign bank accounts; additions based on information from external law enforcement agencies; and matters where prosecution has been filed and is pending.
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Provisions expressly mentioned in the judgment/order text.
Contesting adverse tax judgments on merits required for specified issue categories regardless of monetary thresholds or tax effect.
Adverse tax decisions on specified categories must be contested on merits irrespective of monetary thresholds or absence of tax effect. The amended paragraph directs appeals in cases involving constitutional validity challenges; findings that a Board order, notification, instruction or circular is illegal or ultra vires; accepted Revenue Audit objections; additions for undisclosed foreign income/assets or foreign bank accounts; additions based on information from external law enforcement agencies; and matters where prosecution has been filed and is pending.
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