LON (89/341)

No. 5958

Decision given 9 May 1991.

Assessment – Underdeclaration of tax – Whether assessment made out of time – Whether the assessment made to the best of the judgment of the commissioners – Supplies of gold – Whether gold received by appellant as bailee or trustee – Value Added Tax Act 1983, Sch. 7, para. 4(1) and (5).

  The issue was whether the appellant, who manufactured gold jewellery purchased gold from his customers and then manufactured new jewellery or whether he used the customer’s own gold. Further, whether the assessment was made out of time and not to the best of the commissioners’ judgment.

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