Reasonable Cause for Late Return: penalty under section 271(1)(c) unsustainable where disclosure, audit filing and voluntary offer showed no concealme...
Protective additions made in the society's assessment were held unsustainable because substantially identical diary entries were treated in substantive assessments of the individuals; the adjudicating body applied the peak-credit approach to allocate amounts to each individual and set those amounts off against income they had declared in the survey year. Given that surrendered income was credited to avoid double taxation, the protective addition in the society's hands was deleted on the ground that the same receipts cannot be taxed twice.
Protective additions made in the society's assessment were held unsustainable because substantially identical diary entries were treated in substantive assessments of the individuals; the adjudicating body applied the peak-credit approach to allocate amounts to each individual and set those amounts off against income they had declared in the survey year. Given that surrendered income was credited to avoid double taxation, the protective addition in the society's hands was deleted on the ground that the same receipts cannot be taxed twice.
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