Settlement application eligibility requires a pending assessment when filed, preventing an extra prior-eligibility condition from blocking considerati...
Reassessment for unreturned property sales survives where transfer information, non-filing, and unsupported exemption claims establish a prima facie l...
Profit-element taxation limits additions for unaccounted flat-sale receipts and grey-market purchases, while reliable search records support partial a...
Penalty for under-reported income is not automatically attracted merely because a first return is filed in response to a reassessment notice and accepted without variation. The statutory trigger must be read with the exclusion for a bona fide explanation and full disclosure of material facts. The use of "may" preserves discretion in imposing penalty. Relevant indicators of bona fides include audit-related delay, an undisposed request to file the return, prompt filing after notice, verified declared figures, and payment of tax and interest. Treating bona fides as irrelevant without reasoned consideration is inconsistent with this framework; on the stated facts, the penalty was deleted.
Penalty for under-reported income is not automatically attracted merely because a first return is filed in response to a reassessment notice and accepted without variation. The statutory trigger must be read with the exclusion for a bona fide explanation and full disclosure of material facts. The use of "may" preserves discretion in imposing penalty. Relevant indicators of bona fides include audit-related delay, an undisposed request to file the return, prompt filing after notice, verified declared figures, and payment of tax and interest. Treating bona fides as irrelevant without reasoned consideration is inconsistent with this framework; on the stated facts, the penalty was deleted.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4879 
