Income tax – Check into income tax position – Notice under FA 2008, Sch. 36, para. 1 – Whether officer had ‘reasonable grounds to suspect’ underassessment – No – As not supported by any evidence – Whether certain items statutory records – No – As the time limit had passed – Notice set aside.
The First-tier Tribunal (‘FTT’) set aside a Sch. 36 Information Notice because there was no evidence that the relevant officer had reasonable grounds to suspect an underassessment of tax.