Opportunity to furnish unsecured-loan confirmations is required before reassessment initiation; proceedings require fresh consideration after taxpayer...
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Appellate directions affirmed by the Supreme Court bind the parties and cannot be indirectly challenged through appeals against consequential compliance orders. Orders that merely implement or reiterate directions for fresh consideration, preserve existing interim arrangements, and neither decide the merits nor create new findings affecting rights do not warrant appellate interference. The Tribunal dismissed the connected appeals because they sought to reopen a prior appellate determination that had attained finality.
Appellate directions affirmed by the Supreme Court bind the parties and cannot be indirectly challenged through appeals against consequential compliance orders. Orders that merely implement or reiterate directions for fresh consideration, preserve existing interim arrangements, and neither decide the merits nor create new findings affecting rights do not warrant appellate interference. The Tribunal dismissed the connected appeals because they sought to reopen a prior appellate determination that had attained finality.
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