CMA Final · Direct Tax Laws and International Taxation · Penalties and Prosecutions
A penalty-initiating assessment order is appealed under section 356; the appellate order is received by the jurisdictional Commissioner on 20 May 2027. Ignoring any exclusions under section 472(5), the last date for passing the penalty order under section 472(1)(c) is:
The last date is 31 December 2027. Under section 472(1)(c) the period is six months from the end of the quarter in which the appellate order is received; receipt on 20 May 2027 falls in the quarter ending 30 June 2027.
- A31 December 2027Correct
- B20 November 2027
- C30 September 2027
- D31 March 2028
Explanation
Six months from the end of the quarter in which the order is received applies. 20 May 2027 falls in the quarter ending 30 June 2027. Six months after that is 31 December 2027. 20 November 2027 wrongly counts six months from the date of receipt.
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