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...
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 
