Exclusion of limitation period: pandemic suspension plus debtor acknowledgement can extend limitation, requiring fresh factfinding on guarantee invoca...
Reopening of assessment examines adequacy of service of statutory pre-reopening notice and the right to be heard; the court found doubt as to proper service of the notice under the statute and concluded that the taxpayer was likely deprived of a fair opportunity to present its case, consequently setting aside the subsequent notice and order issued on April 8, 2024. The operative effect requires the taxpayer to file a reply to the show-cause notice dated March 8, 2024 within two weeks, after which the assessing officer must reconsider whether reopening and issuance of a reassessment notice is justified.
Reopening of assessment examines adequacy of service of statutory pre-reopening notice and the right to be heard; the court found doubt as to proper service of the notice under the statute and concluded that the taxpayer was likely deprived of a fair opportunity to present its case, consequently setting aside the subsequent notice and order issued on April 8, 2024. The operative effect requires the taxpayer to file a reply to the show-cause notice dated March 8, 2024 within two weeks, after which the assessing officer must reconsider whether reopening and issuance of a reassessment notice is justified.
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