Consider this example. A Company delivered its tax return and accounts for the accounting period ended on 31 March 2005. HMRC Special Investigations responded quickly with a Notice under FA 1998 Sch 18 para 84. The Company's accountants providing detailed information insisted that the 2005 return and accounts correctly continued previously established practice computing profits under Case 1 Schedule D. Nearly a year later HMRC withdrew the Notice describing it as a 'mistake'. But HMRC substituted a new para 84 notice seeking information which might show whether under para 84(2) the Company's profits might be computed on an alternative basis. The correctness of the Company's 2005 return was no longer challenged. But Special Investigations at the same time issued a Notice under TMA 1970 s 20(8A) as amended requiring disclosure of documents from which it might be able to judge whether...
