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...
Penalty under section 271(1)(c) cannot rest on a disallowance of business interest on secured promissory notes once the underlying quantum disallowance has been reversed. Interest on those notes was treated as incurred for business purposes and therefore not deductible only on an unsustainable basis. The Tribunal's deletion of penalty was upheld because the issue was initially debatable and the quantum position later attained finality. With no surviving basis for the disallowance, the penalty could not continue, and the Revenue's appeals were dismissed.
Penalty under section 271(1)(c) cannot rest on a disallowance of business interest on secured promissory notes once the underlying quantum disallowance has been reversed. Interest on those notes was treated as incurred for business purposes and therefore not deductible only on an unsustainable basis. The Tribunal's deletion of penalty was upheld because the issue was initially debatable and the quantum position later attained finality. With no surviving basis for the disallowance, the penalty could not continue, and the Revenue's appeals were dismissed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4915 
