Provisional Assessment Stays Provisional; Parties Can Appeal Denied Benefits Later, Even If Not Initially Contested.

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Full Text of the Document

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....An assessment which is provisional, is provisional for all purposes. There is no provision in law to treat the same assessment as provisional for one purpose and final for another. Even if the respondent had not protested against denial of the benefit of the notification during finalization of the assessment, it does not stop them from claiming the benefit subsequently by filing an appeal against the assessment.....