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...
Reasoned and speaking appellate orders require consideration of the appellants' material grounds and cited authorities; a bare affirmation of original orders in identical terms fails to exercise appellate jurisdiction. Where original adjudication proceeded ex parte and objections concerning notice, relied-upon documents, and personal hearing remain unexamined, remand preserves the effective appellate remedy rather than a merits decision at the appellate stage. The appellate and original orders were set aside, with fresh adjudication requiring identification and availability of relied-upon documents, reasonable time to reply, an effective personal hearing, and reasoned orders.
Reasoned and speaking appellate orders require consideration of the appellants' material grounds and cited authorities; a bare affirmation of original orders in identical terms fails to exercise appellate jurisdiction. Where original adjudication proceeded ex parte and objections concerning notice, relied-upon documents, and personal hearing remain unexamined, remand preserves the effective appellate remedy rather than a merits decision at the appellate stage. The appellate and original orders were set aside, with fresh adjudication requiring identification and availability of relied-upon documents, reasonable time to reply, an effective personal hearing, and reasoned orders.
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