Limitation for redetermination: re-determination must be completed within two years and confined to timely-issued non-fraud demands. When an appellate direction deems a fraud-based notice to be a non-fraud notice, the proper officer must issue the redetermination order of tax, interest and penalty within two years from communication of that direction. The redetermination must follow the non-fraud show cause framework and is limited to amounts for which the original notice was issued within the non-fraud time limit; notices issued beyond that time bar must be dropped, and for multi-year notices only amounts from years within the non-fraud limitation may be redetermined.
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.
Limitation for redetermination: re-determination must be completed within two years and confined to timely-issued non-fraud demands.
When an appellate direction deems a fraud-based notice to be a non-fraud notice, the proper officer must issue the redetermination order of tax, interest and penalty within two years from communication of that direction. The redetermination must follow the non-fraud show cause framework and is limited to amounts for which the original notice was issued within the non-fraud time limit; notices issued beyond that time bar must be dropped, and for multi-year notices only amounts from years within the non-fraud limitation may be redetermined.
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