Enquiry adjustment

I am dealing with a tax enquiry where the only adjustment is the add-back for private motoring.

For some reason we omitted to make an add-back adjustment in the last set of accounts submitted (which happen to be cessation accounts).

For previous years the add-back was approximately £750 per year on a ‘round sum’ basis.

The Inspector is not content with adjusting for the existing year and is seeking to adjust the previous four years with net adjustments of between £1 500 and £3 500 per annum.

I have made the point to the Inspector that I have never come across a case where HMRC have sought to amend previous years for private use add-backs as the enquiry window has closed.

I have referred the Inspector to ESC A19 but the Inspector will not budge.

Can Taxation readers please advise whether the Inspector is entitled to adjust earlier...