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...
Levy of tax penalty was quashed because the penalty proceedings were founded on a legally defective, non specific show cause notice that merely alleged failure to comply with unspecified notices, preventing a proper opportunity to explain. The assessment that spawned the penalty was set aside and remitted for de novo assessment, and the penalty order relied on incorrect factual premises about compliance. On these procedural fairness grounds the Tribunal held the show cause notice invalid and deleted the penalty under the applicable penalty provision.
Levy of tax penalty was quashed because the penalty proceedings were founded on a legally defective, non specific show cause notice that merely alleged failure to comply with unspecified notices, preventing a proper opportunity to explain. The assessment that spawned the penalty was set aside and remitted for de novo assessment, and the penalty order relied on incorrect factual premises about compliance. On these procedural fairness grounds the Tribunal held the show cause notice invalid and deleted the penalty under the applicable penalty provision.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4915 
