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Bona fide disclosure requirements govern under-reporting penalties, and post-penalty immunity applications cannot secure available statutory protection.
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Bona fide explanation and full disclosure of material facts are required for exclusion from penalty for under-reported interest income. The note states that an explanation based on revision of tax-credit information fails where bank-reported gross interest remained unchanged and the original return disclosed less interest than the original statement. It therefore records that the under-reporting penalty was sustained. It also explains that the prescribed period for filing the immunity application in Form No. 68 is mandatory: an application filed after the penalty order cannot survive. The rejection of post-penalty immunity was accordingly upheld, and the appeal was dismissed.
Bona fide explanation and full disclosure of material facts are required for exclusion from penalty for under-reported interest income. The note states that an explanation based on revision of tax-credit information fails where bank-reported gross interest remained unchanged and the original return disclosed less interest than the original statement. It therefore records that the under-reporting penalty was sustained. It also explains that the prescribed period for filing the immunity application in Form No. 68 is mandatory: an application filed after the penalty order cannot survive. The rejection of post-penalty immunity was accordingly upheld, and the appeal was dismissed.
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