In U Chaudhary v HMRC [2019] UKFTT 99 (14 February 2019) the FTT found that a discovery had not become stale when assessments were finally issued following the failure of negotiations with the taxpayer.
Mr Chaudhary carried on a second-hand car sales business. HMRC opened an enquiry into his return for the year 2010/11 and concluded that his profits had been understated. It therefore amended his self-assessment return and issued discovery assessments for the years 2008/09 2009/10 and 2011/12. In addition HMRC imposed penalties on the basis that the inaccuracies in the returns were deliberate and concealed.
During the course of the enquiry HMRC had pressed Mr Chaudhary to confirm that he had disclosed all his bank accounts and asked him repeatedly to sign a ‘certificate of bank accounts operated’. He eventually signed the certificate in January 2015 having previously inferred that he had disclosed all...
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