Commentary

A6.712 Discovery—challenging an assessment

Administration and compliance

A6.712 Discovery—challenging an assessment

A6.712 Discovery—challenging an assessment

Note that the commentary below refers only to the legislation as it applies to individuals, but unless otherwise stated, it can be assumed that it will also apply to partnerships and companies.

Where a taxpayer wishes to appeal against a discovery assessment he may wish to appeal both on the grounds that HMRC had not met the tests for the issue of an assessment and also on the substantive grounds of the content of the assessment itself. TMA 1970, s 29(8) specifies that an objection to the making of an assessment under this section on the grounds that neither of the two conditions within TMA 1970, s 29 above (careless/deliberate behaviour — see A6.709, or available

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