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...
Extended limitation was held applicable because the investigation materials showed wilful misstatement and suppression of facts, including diversion of duty-free imports, use of an incorrect export code, and alleged manipulation of export documentation. The plea that the discrepancy was merely clerical was rejected, and the show cause notice was treated as timely. The requirement of pre-deposit was also upheld as reasonable because the appellants could not rely on parity with an earlier order involving different facts and limited bills of entry. On that basis, the direction to deposit amounts and the dismissal of the appeals for non-compliance were sustained.
Extended limitation was held applicable because the investigation materials showed wilful misstatement and suppression of facts, including diversion of duty-free imports, use of an incorrect export code, and alleged manipulation of export documentation. The plea that the discrepancy was merely clerical was rejected, and the show cause notice was treated as timely. The requirement of pre-deposit was also upheld as reasonable because the appellants could not rely on parity with an earlier order involving different facts and limited bills of entry. On that basis, the direction to deposit amounts and the dismissal of the appeals for non-compliance were sustained.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4915 
