HMRC Local Compliance have just opened a "compliance check" into a 2012 tax return submitted in April 2012. This is therefore outwith the period to enquire into the return. Unable to find any guidance that permits them to do this. Any thoughts?
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Discovery
HMRC may make a 'discovery' assessment under section 29 TMA 1970. Otherwise to re-open cases outside the normal time limit, HMRC have to show careless or deliberate actions of the taxpayer.
Perhaps the short answer will be to ask why HMRC have opened a compliance check since you consider the period for enquiry is now closed.