SCIT Assessment – Discovery assessment under s.29(1) TMA – Whether assessment precluded by section 29(5)TMA
Assessment – Discovery assessment under s.29(1) TMA – Whether s.3 HRA requires section 29 to be read differently – Whether HMRC’s actions in relation to the appellant and section 29 were incompatible with Convention rights
Assessment – Whether made
Section 16(2A) TCGA 1992, and section 71(2)TCGA – Was a taxpayer prevented from arguing that a loss was an allowable loss in his hands because it had been disallowed by HMRC in the hands of the trustees – held : no.
Citations:
[2008] UKSPC SPC00692
Links:
Income Tax
Updated: 19 July 2022; Ref: scu.273100