Business reorganisation requires recognition of successor's modified return; draft orders against dissolved transferor quashed and fresh review direct...
Pre-commencement R&D deduction denied where business had not commenced; deeming benefit requires tangible start of manufacture or commercial exploitat...
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.
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TaxTMI 
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TaxTMI 
