Contingency expenses, exempt-income disallowance, and royalty benchmarking: unsupported adjustments were deleted under consistent accounting and trans...
Disciplinary proportionality requires penalties for Authorised Representative misconduct to match proven harm, leading to reconsideration of registrat...
Service of a valid reassessment notice is a jurisdictional condition precedent to reopening an assessment. The Assessing Officer bears the burden of proving actual service; absence of a valid postal receipt or other reliable proof leaves the jurisdictional requirement unsatisfied. Filing a return and participating in proceedings following an inquiry notice cannot cure non-service through consent, waiver or estoppel. Non-service is an incurable jurisdictional defect, rendering the reassessment proceedings and consequential assessment void ab initio.
Service of a valid reassessment notice is a jurisdictional condition precedent to reopening an assessment. The Assessing Officer bears the burden of proving actual service; absence of a valid postal receipt or other reliable proof leaves the jurisdictional requirement unsatisfied. Filing a return and participating in proceedings following an inquiry notice cannot cure non-service through consent, waiver or estoppel. Non-service is an incurable jurisdictional defect, rendering the reassessment proceedings and consequential assessment void ab initio.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
