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...
Issue concerns validity of a transfer order and subsequent assessment where the transferring authority lacked jurisdiction. The tribunal found that transfer provisions apply only when the assessing officer is vested with jurisdiction following a valid direction; absent jurisdiction, objection under the transfer provision cannot arise. The transfer order issued by a non-jurisdictional officer was held void ab initio, and consequential proceedings including the final assessment were without jurisdiction and therefore quashed. Failure to communicate the transfer order to the taxpayer until tribunal proceedings was noted as reinforcing the invalidity of the transfer and downstream assessment.
Issue concerns validity of a transfer order and subsequent assessment where the transferring authority lacked jurisdiction. The tribunal found that transfer provisions apply only when the assessing officer is vested with jurisdiction following a valid direction; absent jurisdiction, objection under the transfer provision cannot arise. The transfer order issued by a non-jurisdictional officer was held void ab initio, and consequential proceedings including the final assessment were without jurisdiction and therefore quashed. Failure to communicate the transfer order to the taxpayer until tribunal proceedings was noted as reinforcing the invalidity of the transfer and downstream assessment.
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