Commitment proceedings gain extended timelines, structured defect refiling, and automatic resumption of inquiry after the adjusted completion period e...
Centralised assessment transfer becomes unwarranted once the searched person's assessment is complete, requiring restoration to the appropriate charge...
Reopening of assessment under the new regime requires supplying to the taxpayer the materials forming the basis for reopening; where only a notice and reasons recorded were provided without annexed material, the taxpayer was deprived of an effective opportunity to respond and the subsequent order under the new procedure was invalidated. The note emphasises that failure to furnish underlying information precludes meaningful representation and renders the reopening notice defective, aligning with higher-court guidance that materials must be disclosed before final action is taken.
Reopening of assessment under the new regime requires supplying to the taxpayer the materials forming the basis for reopening; where only a notice and reasons recorded were provided without annexed material, the taxpayer was deprived of an effective opportunity to respond and the subsequent order under the new procedure was invalidated. The note emphasises that failure to furnish underlying information precludes meaningful representation and renders the reopening notice defective, aligning with higher-court guidance that materials must be disclosed before final action is taken.
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