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...
Principles of issue estoppel and administrative finality constrain a subordinate appellate authority from revisiting or nullifying its earlier appellate findings when granting consequential relief; the commentary applies res judicata and Evidence Act principles by analogy to quasi judicial tax proceedings and rejects re litigation where the appellate order was accepted by the department. The noted decision found the Commissioner (Appeals) improperly refused relief already adjudicated in an earlier Appellate Order, set aside that refusal, and remitted the matters for fresh consideration on merits while prohibiting re opening settled appellate conclusions.
Principles of issue estoppel and administrative finality constrain a subordinate appellate authority from revisiting or nullifying its earlier appellate findings when granting consequential relief; the commentary applies res judicata and Evidence Act principles by analogy to quasi judicial tax proceedings and rejects re litigation where the appellate order was accepted by the department. The noted decision found the Commissioner (Appeals) improperly refused relief already adjudicated in an earlier Appellate Order, set aside that refusal, and remitted the matters for fresh consideration on merits while prohibiting re opening settled appellate conclusions.
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TaxTMI 
TaxTMI 
of 4915 
