Challenging the presumption of continuity

Challenging the presumption of continuity

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HMRC opened an inquiry into one year and purported to find a cash discrepancy (challenged by taxpayer, a self-employed repairman), asserted to be undisclosed profits. Refusal to accept proposed adjustment was followed by similar adjustments for EARLIER years. All years are now before Commissioners, where HMRC are relying on Jonas v Bamford (dictum at end of Walton J's judgment about "usual presumption of continuity"). However in this case, the adjustments were made to LATER years. Can it be argued that the presumption only goes forwards?
keith deane

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