Human-probability test defeats political donation deductions where banking records mask accommodation-entry fund layering rather than genuine contribu...
Under-reporting penalty requires assessed income to exceed the income determined on processing the return. Where reassessment accepts the income declared in the original return without any addition or disallowance, no income variation exists to constitute under-reported income and the statutory conditions for penalty are not met. The penalty is therefore unsustainable, the appellate order sustaining it is set aside, and deletion of the penalty follows.
Under-reporting penalty requires assessed income to exceed the income determined on processing the return. Where reassessment accepts the income declared in the original return without any addition or disallowance, no income variation exists to constitute under-reported income and the statutory conditions for penalty are not met. The penalty is therefore unsustainable, the appellate order sustaining it is set aside, and deletion of the penalty follows.
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