Notes:
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INCOME TAX –discovery assessment –tax avoidance scheme –ground of appeal against the quantum of assessment and not the efficacy of the scheme –ss 29 and 34 of Taxes Management Act 1970 –whether assessment validly made –pre-condition under s 29(5) –whether a hypothetical officer could have been reasonably expected to be aware of the insufficiency from the information made available; no –whether assessment stands good; yes –onus for displacing assessment regarding quantum on the appellant –appeal dismissed |