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Notes:
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CORPORATION TAX – declaration under s.153A TCGA 1992 (business assets roll-over relief) ceasing to have effect – s.153A(4) providing that all necessary adjustment shall be made – whether that provides for a ‘freestanding’ power or alternatively incorporates a reference to the assessment and amendment powers in Sch. 18, FA 1998 – held s.153A(4) TCGA incorporates such a reference – HMRC’s decision under s.153A(4), the
subject of the appeal, purporting to be an amendment to the Appellant’s selfassessment in its company tax return, of no effect as no power under Sch. 18 FA 1998 enabled the making of it – there being no provision for an appeal against that decision, the Tribunal had no jurisdiction to entertain the appeal and the appeal is therefore struck out |
