Opportunity to furnish unsecured-loan confirmations is required before reassessment initiation; proceedings require fresh consideration after taxpayer...
Under-reporting on a first reassessment return attracts penalty, while enhanced misreporting penalty requires proof of a statutory misreporting catego...
Show cause notices issued in the name of a deceased taxable person are void because tax cannot be determined against a non-existent person. Although legal representatives are liable only to the extent of the deceased's estate, that liability requires assessment against them in their representative capacity. They must receive a fresh notice and a meaningful opportunity to reply and be heard before liability is determined. Proceedings initiated solely against a deceased proprietor, including adjudication and recovery, are liable to be quashed and remitted for fresh adjudication against the legal representatives without determination on merits.
Show cause notices issued in the name of a deceased taxable person are void because tax cannot be determined against a non-existent person. Although legal representatives are liable only to the extent of the deceased's estate, that liability requires assessment against them in their representative capacity. They must receive a fresh notice and a meaningful opportunity to reply and be heard before liability is determined. Proceedings initiated solely against a deceased proprietor, including adjudication and recovery, are liable to be quashed and remitted for fresh adjudication against the legal representatives without determination on merits.
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