Jurisdictional satisfaction for concealment penalty cannot be created later by substituting a distinct penal provision after assessment.

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....Jurisdictional satisfaction for penalty under section 271(1)(c) must be recorded during assessment, including a direction to initiate penalty under that provision where deemed satisfaction is invoked. Initiation under section 271AAC, a distinct provision with separate conditions and consequences, cannot support a later notice or penalty under section 271(1)(c). A subsequent penalty order cannot amend the assessment order or retrospectively create foundational jurisdiction. The penalty was therefore deleted, while the quantum appeal remained for independent determination on merits.....