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...
Government departments remain equally bound by limitation requirements in Customs Act appeals. Vague assertions that earlier counsel caused delay do not establish sufficient cause where the department cannot explain file transfer, follow-up, retrieval, or inconsistencies over documents allegedly supplied. Administrative inaction, lethargic internal functioning, and an unsubstantiated effort to attribute delay wholly to counsel cannot justify condonation. In the absence of a reasonable explanation, the delay-condonation application was dismissed and the Customs Act appeal stood disposed of.
Government departments remain equally bound by limitation requirements in Customs Act appeals. Vague assertions that earlier counsel caused delay do not establish sufficient cause where the department cannot explain file transfer, follow-up, retrieval, or inconsistencies over documents allegedly supplied. Administrative inaction, lethargic internal functioning, and an unsubstantiated effort to attribute delay wholly to counsel cannot justify condonation. In the absence of a reasonable explanation, the delay-condonation application was dismissed and the Customs Act appeal stood disposed of.
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TaxTMI 
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