Easinghall Limited v Revenue and Customs Commissioners

Income tax – Assessment. The Upper Tribunal (Tax and Chancery Chamber) (the tribunal) allowed the appeal by Easinghall Ltd (EL) against a decision of the First-tier Tribunal (Tax Chamber), refusing EL's application for a direction that the Revenue close an enquiry it had opened into EL's 2011/12 tax return. The tribunal held that the earlier review carried out by one of the Revenue's officer's into EL's 2011/12 tax return had been settled by agreement under s 54(1) of the Taxes Management Act 1970 with the result that the Revenue could not amend that return as a result of an enquiry into the same matter in the light of that settlement.

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