Reopening assessments based on audit objections: preserve initiated reassessments and prefer supervisory revision where feasible. The Board instructs that reassessment proceedings already initiated on the basis of audit objections must not be dropped pending review of a court decision questioning whether audit objections constitute information sufficient to reopen assessments; the scope of that decision is under consideration with the Ministry of Law. For future remedial action, authorities should, where feasible, prefer exercise of supervisory revision powers rather than initiating reassessment under the reopening provision.
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.
Reopening assessments based on audit objections: preserve initiated reassessments and prefer supervisory revision where feasible.
The Board instructs that reassessment proceedings already initiated on the basis of audit objections must not be dropped pending review of a court decision questioning whether audit objections constitute information sufficient to reopen assessments; the scope of that decision is under consideration with the Ministry of Law. For future remedial action, authorities should, where feasible, prefer exercise of supervisory revision powers rather than initiating reassessment under the reopening provision.
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