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...
Recall of ex parte orders requires a showing of sufficient cause for non-appearance, whereas review is confined to an error apparent on the face of the record. The Tribunal found no sufficient cause where repeated opportunities had been granted, including a final opportunity after the applicant was already proceeded ex parte, yet the applicant remained absent. Illness and death in one partner's family and lapse of previous counsel were held insufficient, especially when other partners of the firm also gave no explanation. The request to place additional material on record, including a later Supreme Court decision, was not considered because recall itself failed. The recall applications were dismissed.
Recall of ex parte orders requires a showing of sufficient cause for non-appearance, whereas review is confined to an error apparent on the face of the record. The Tribunal found no sufficient cause where repeated opportunities had been granted, including a final opportunity after the applicant was already proceeded ex parte, yet the applicant remained absent. Illness and death in one partner's family and lapse of previous counsel were held insufficient, especially when other partners of the firm also gave no explanation. The request to place additional material on record, including a later Supreme Court decision, was not considered because recall itself failed. The recall applications were dismissed.
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TaxTMI 
TaxTMI 
of 4915 
