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...
Doctrine of merger applied to impugned order of Appellate Tribunal imposing penalty on appellant. Held that since Supreme Court's judgment on appeal against Tribunal's order, doctrine of merger renders Tribunal's order subsumed into apex court's judgment. Consequently, no question of law arises from Tribunal's order for consideration regarding perversity, jurisdiction to levy penalty or discretion exercised. Application dismissed as Tribunal's order has merged into Supreme Court's judgment under Article 136.
Doctrine of merger applied to impugned order of Appellate Tribunal imposing penalty on appellant. Held that since Supreme Court's judgment on appeal against Tribunal's order, doctrine of merger renders Tribunal's order subsumed into apex court's judgment. Consequently, no question of law arises from Tribunal's order for consideration regarding perversity, jurisdiction to levy penalty or discretion exercised. Application dismissed as Tribunal's order has merged into Supreme Court's judgment under Article 136.
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