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HMRC investigated two companies focussing on the corporation tax returns for a certain accounting period. Requests were made for documents and information, but these were not produced.
So the inspector applied for notices to be issued under TMA 1970, s 20 and permission was granted by the General Commissioners. Notices in the form of standard form letters were subsequently issued to the companies.
The directors of the companies applied for judicial review claiming that s 20(8E) had not been complied with.
The High Court said that the notices contained written summaries of reasons for their issue as stated by the authorised inspector who has issued them. The procedure had been followed.
The directors’ application for judicial review was dismissed.
