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...
A penalty under tax law was quashed because the initiating notice failed to specify which limb of the penalty provision applied and did not strike out the inapplicable limb; the procedural defect meant the penalty order proceeded without a valid notice. The commentary highlights that notices must identify the specific limb relied on (distinguishing furnishing inaccurate particulars from concealment) and that failure to do so vitiates penalty proceedings. The practical effect is that penalties based on such defective notices are invalid and liable to be set aside.
A penalty under tax law was quashed because the initiating notice failed to specify which limb of the penalty provision applied and did not strike out the inapplicable limb; the procedural defect meant the penalty order proceeded without a valid notice. The commentary highlights that notices must identify the specific limb relied on (distinguishing furnishing inaccurate particulars from concealment) and that failure to do so vitiates penalty proceedings. The practical effect is that penalties based on such defective notices are invalid and liable to be set aside.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4915 
