Notice specificity is required: failure to identify and exclude the inapplicable limb vitiates tax penalty proceedings and leads to quashing.

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....A penalty under tax law was quashed because the initiating notice failed to specify which limb of the penalty provision applied and did not strike out the inapplicable limb; the procedural defect meant the penalty order proceeded without a valid notice. The commentary highlights that notices must identify the specific limb relied on (distinguishing furnishing inaccurate particulars from concealment) and that failure to do so vitiates penalty proceedings. The practical effect is that penalties based on such defective notices are invalid and liable to be set aside.....