INCOME TAX/CORPORATION TAX – discovery assessments – competence issues – TMA, s 29 and FA 1998, Sch 18, paras 41-43 – time limit issues – TMA, s 36(1A) and FA 1998, Sch 18, para 46(2A) – whether failure by FTT to consider competence and time limit issues was an error of law – whether issues were required to be raised by HMRC or appellants – burden of proof – appeal allowed – whether to remit to FTT – case not remitted
References: [2015] UKUT 578 (TCC)
Links: Bailii
Jurisdiction: England and Wales
Last Update: 16 October 2020; Ref: scu.558941 br>