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Revisability of return invalidation communications under tax procedure affirmed, impugned non revisional finding quashed and matter remitted for fresh...
An admitted acknowledgment of liability can give rise to a fresh starting point of limitation, and the court-closure rule applies when the last day falls on a weekend and filing is made on the reopening day. The tribunal also clarified that the default-proof requirement is not confined to information-utility records: prima facie disclosure of debt and default may be shown through balance-sheet admissions and the debtor's written statement. A new limitation plea cannot be raised for the first time in written submissions after arguments, because written submissions are not pleadings.
An admitted acknowledgment of liability can give rise to a fresh starting point of limitation, and the court-closure rule applies when the last day falls on a weekend and filing is made on the reopening day. The tribunal also clarified that the default-proof requirement is not confined to information-utility records: prima facie disclosure of debt and default may be shown through balance-sheet admissions and the debtor's written statement. A new limitation plea cannot be raised for the first time in written submissions after arguments, because written submissions are not pleadings.
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