Electronic evidence and search statements in tax assessments require authenticity review and corroboration, while procedural manuals lack statutory fo...
Tariff rate quota authorisations govern preferential imports of specified New Zealand goods through export certification and electronic customs debiti...
Electronic Continuity Bond Registration replaces manual container permissions, with quarterly reporting and re-export monitoring for duty-free contain...
Revision under section 263 may apply where reassessment of alleged bogus purchases lacks requisite verification. Supplier non-response, failure to furnish requested confirmations, evidence of goods movement and transporter payments, and the Assessing Officer's failure to undertake follow-up inquiry indicate inadequate inquiry. Mere issuance of notices and receipt of partial material do not constitute an inquiry reaching a conclusion under Explanation 2(a). An unreasoned profit-rate estimate does not represent a legally sustainable plausible view or a concluded opinion protected by change-of-opinion principles, rendering the assessment erroneous and prejudicial to the interests of the Revenue.
Revision under section 263 may apply where reassessment of alleged bogus purchases lacks requisite verification. Supplier non-response, failure to furnish requested confirmations, evidence of goods movement and transporter payments, and the Assessing Officer's failure to undertake follow-up inquiry indicate inadequate inquiry. Mere issuance of notices and receipt of partial material do not constitute an inquiry reaching a conclusion under Explanation 2(a). An unreasoned profit-rate estimate does not represent a legally sustainable plausible view or a concluded opinion protected by change-of-opinion principles, rendering the assessment erroneous and prejudicial to the interests of the Revenue.
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