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...
Non-participating bidders cannot disturb concluded liquidation sales on speculative prejudice, while costs for such challenges must remain proportiona...
Penalty proceedings for undisclosed income found during a search require a notice under section 274 that identifies the precise charge under section 271AAB, including the applicable statutory clause and corresponding penalty rate. This specificity is necessary to provide a meaningful opportunity of hearing. A notice that merely refers generally to undisclosed income and proposed penalty under section 271AAB, without identifying the relevant conditions, is vague and invalid. Defective initiation notices invalidate consequential penalty proceedings; the penalty is deleted, leaving the substantive merits of the levy unexamined.
Penalty proceedings for undisclosed income found during a search require a notice under section 274 that identifies the precise charge under section 271AAB, including the applicable statutory clause and corresponding penalty rate. This specificity is necessary to provide a meaningful opportunity of hearing. A notice that merely refers generally to undisclosed income and proposed penalty under section 271AAB, without identifying the relevant conditions, is vague and invalid. Defective initiation notices invalidate consequential penalty proceedings; the penalty is deleted, leaving the substantive merits of the levy unexamined.
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