Limitation on re determination of tax: redetermination is confined to amounts for which non fraud notices were timely issuable and completed within prescribed time. An order to re determine tax, interest and penalty under the non fraud show cause framework must be issued within the two year period prescribed following communication of an appellate direction. Re determination is limited to amounts for which a non fraud notice could lawfully have been issued within the non fraud limitation window measured from the due date for filing the relevant annual return or the date of any erroneous refund; amounts outside that window must be dropped.
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 on re determination of tax: redetermination is confined to amounts for which non fraud notices were timely issuable and completed within prescribed time.
An order to re determine tax, interest and penalty under the non fraud show cause framework must be issued within the two year period prescribed following communication of an appellate direction. Re determination is limited to amounts for which a non fraud notice could lawfully have been issued within the non fraud limitation window measured from the due date for filing the relevant annual return or the date of any erroneous refund; amounts outside that window must be dropped.
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