The tribunal examined whether penalties could continue when the fresh assessment order did not record satisfaction for initiating them. It ruled that absence of such satisfaction makes the penalties invalid in law.
The tribunal considered whether total bank credits could be added as unexplained money. It held that when deposits are consistent with declared turnover and business activity, they cannot be treated as unexplained income.
The tribunal noted discrepancies in the dispatch register used to prove issuance of the notice. Because the records did not inspire confidence, the tribunal held the reassessment notice to be time-barred.
