Timothy J A Norton & Tim Norton Motor Services Ltd v The Commissioners for HM Revenue and Customs [2023] UKUT 00048 (TCC)
Upper Tribunal Tax and Chancery decision of Judge Greg Sinfield and Judge Nicholas Paines KC on 23 February 2023
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INCOME TAX and NICs – benefits in kind – ss 114 -148 ITEPA – car benefits – whether SORN meant car was not made available – discovery assessment – s 29 TMA – whether validly raised before officer ceased to be entitled to enquire into taxpayer’s return – closure notice – ss 28A, 114 TMA – whether defect of form cured by s 114