[EM3232] Discovery: making a discovery – whether there is a discovery: making an assessment – qualifying conditions – careless or deliberate behaviour
Making an assessment
The HMRC officer who makes the discovery may then make an assessment.
The discovery provisions act as an additional qualifying condition for making an assessment. The assessing officer must first have discovered an insufficiency. This means that the assessing officer must first examine the evidence and reach the opinion, that is discover, that there is a loss of tax.
The officer should record when they reached their conclusion and the basis for that conclusion.
The officer who makes the decision to assess is considered to have made the assessment.