I refer to Paul Soper's letter Flawed guidance?
As someone who regularly challenges adjustments upon closure of an enquiry simply on the basis that the statutory requirements have not been complied with I fully endorse Paul's suggestion that tax advisers set up accurate records so that the closure of the enquiry window can be closely monitored.
In other words the precautions that advisers have tended to take in the last week of January should be now extended to all tax returns whenever submitted.
In one recent case before the General Commissioners HMRC were valiantly trying to rely upon the date stamp on the front of the tax return to support their 'late' opening of an enquiry whilst we had evidence from the accountant and Royal Mail's head office that showed conclusively that the return had been submitted by the relevant 31 January.
However...
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