Reasonable Cause for Late Return: penalty under section 271(1)(c) unsustainable where disclosure, audit filing and voluntary offer showed no concealme...
Proceeds of crime and property equivalent in value: failure to explain lawful source sustains attachment; lack of required notice can vitiate confirma...
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The issue concerns levy of a statutory penalty where income from cash seized during search was treated as unexplained additions under the relevant unexplained income provision. The tribunal applied the statutory test linking that unexplained income to the penalty provision and found no credible explanation, reasonable cause, or material to attract the exclusionary clause; consequently the statutory conditions for non-levy were not satisfied and the penalty was sustained. Disclosure during search was held insufficient to negate liability once judicial determination classified the cash as unexplained income, and the appeal was dismissed.
The issue concerns levy of a statutory penalty where income from cash seized during search was treated as unexplained additions under the relevant unexplained income provision. The tribunal applied the statutory test linking that unexplained income to the penalty provision and found no credible explanation, reasonable cause, or material to attract the exclusionary clause; consequently the statutory conditions for non-levy were not satisfied and the penalty was sustained. Disclosure during search was held insufficient to negate liability once judicial determination classified the cash as unexplained income, and the appeal was dismissed.
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