[2024] UKUT 00436 (TCC)

These grounds are that the HMRC Officer had insufficient information on which to make a discovery assessment.

I reject this ground as unarguable. The FTT was entitled to make the decision that it did on the evidence available to it for the reasons it gave at [55]-[68] of the Decision. The FTT accepted that HMRC’s assessing officer believed, and a reasonable officer would have formed the view, that there had been a loss of tax based on the information available. Therefore, the subjective and objective grounds on which to make a discovery assessment under section 29 TMA 1970 were satisfied.