[2009] CSOH 137.

Court of Session (Outer House).

Lord Bannatyne.

Judgment delivered 7 October 2009.

Income tax – Assessment – Discovery assessment – Discovery notice – Judicial review – Tax inspector issuing discovery notice to taxpayer – Taxpayer challenging decision as wrong in law and unreasonable – Whether HMRC entitled to make discovery assessment having regard to information in tax return – Whether HMRC entitled to serve discovery notice – Petition refused – Taxes Management Act 1970, s. 20(1), (2), 29(1), (3), (5), (6).

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