Concessional penalty for search-disclosed unreconciled jewellery applies where substantive disclosure conditions are met despite omission from origina...
Reopening after a scrutiny assessment was invalid where the recorded reasons incorrectly stated that the return had only been processed under limited processing and, on that false premise, invoked the deeming escapement provision. Because the original assessment had in fact been completed under scrutiny assessment, the Tribunal held that the recorded reasons disclosed clear non-application of mind. The reassessment proceedings were therefore held void ab initio, bad in law and quashed.
Reopening after a scrutiny assessment was invalid where the recorded reasons incorrectly stated that the return had only been processed under limited processing and, on that false premise, invoked the deeming escapement provision. Because the original assessment had in fact been completed under scrutiny assessment, the Tribunal held that the recorded reasons disclosed clear non-application of mind. The reassessment proceedings were therefore held void ab initio, bad in law and quashed.
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