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Opportunity to furnish unsecured-loan confirmations is required before reassessment initiation; proceedings require fresh consideration after taxpayer clarification.
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Reassessment proceedings concerning unsecured loans required an opportunity for the taxpayer to furnish confirmations from lenders and any further particulars needed to determine whether reassessment was warranted. Without that opportunity, the reassessment-initiation order, prior approval and consequential notice were quashed. Fresh consideration was directed after the taxpayer could provide the requisite clarifications and lender confirmations.
Reassessment proceedings concerning unsecured loans required an opportunity for the taxpayer to furnish confirmations from lenders and any further particulars needed to determine whether reassessment was warranted. Without that opportunity, the reassessment-initiation order, prior approval and consequential notice were quashed. Fresh consideration was directed after the taxpayer could provide the requisite clarifications and lender confirmations.
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