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...
For proceedings after an assessee's death, the governing expression is legal representative, not legal heir, and it extends beyond succession-law heirs to persons representing or intermeddling with the estate. On that basis, service of notice on the petitioner in his declared representative capacity was valid, and he could not later challenge it merely because he was not a Class I heir. However, where reassessment was initiated by invoking the extended limitation period, sanction had to be obtained from the authority specified under Section 151(ii). Approval granted by the Principal Commissioner instead of the Principal Chief Commissioner did not satisfy the statutory requirement, so the reassessment notice was quashed for want of competent approval.
For proceedings after an assessee's death, the governing expression is legal representative, not legal heir, and it extends beyond succession-law heirs to persons representing or intermeddling with the estate. On that basis, service of notice on the petitioner in his declared representative capacity was valid, and he could not later challenge it merely because he was not a Class I heir. However, where reassessment was initiated by invoking the extended limitation period, sanction had to be obtained from the authority specified under Section 151(ii). Approval granted by the Principal Commissioner instead of the Principal Chief Commissioner did not satisfy the statutory requirement, so the reassessment notice was quashed for want of competent approval.
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TaxTMI 
TaxTMI 
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