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...
Proof of service and acknowledgment of statutory summons are necessary to support an allegation of deliberate or wilful non-compliance during an investigation. Mere issuance of summons, without material establishing that the person concerned received and acknowledged them, does not establish intentional disobedience or evasion of appearance. On those facts, declining cognizance of the complaint was treated as free from jurisdictional error. Fresh summons may be issued where legally permissible, provided they are duly served and proof of service is maintained. No conclusion follows on the merits of the investigation or on any underlying liability or offence.
Proof of service and acknowledgment of statutory summons are necessary to support an allegation of deliberate or wilful non-compliance during an investigation. Mere issuance of summons, without material establishing that the person concerned received and acknowledged them, does not establish intentional disobedience or evasion of appearance. On those facts, declining cognizance of the complaint was treated as free from jurisdictional error. Fresh summons may be issued where legally permissible, provided they are duly served and proof of service is maintained. No conclusion follows on the merits of the investigation or on any underlying liability or offence.
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