There are restrictions on making discovery assessments. You can only make a discovery assessment for an accounting period for which a company has delivered a company tax return if Paragraphs 43 or 44 apply as below.
1. Paragraph 43 states that when a company has delivered a company tax return you can make a discovery assessment if the underassessment or excessive relief was brought about by the careless or deliberate behaviour of:
•a person acting on behalf of the company, or
•a person who was a partner of the company at the relevant time.