RIZVI v Revenue & Customs (Discovery assessment - whether underassessment of income tax brought about by taxpayer's carelessness)

Discovery assessment - sections 29 and 36 Taxes Management Act 1970 - whether underassessment of income tax brought about by taxpayer�s carelessness - no - whether brought about by carelessness on the part of a person acting on behalf of the taxpayer - yes - appeal dismissed

For the Respondents: �� Miss Rebecca Arnold, litigator of HM Revenue and Customs� Solicitor�s Office

             The basic facts are not in dispute and are as follows:

(1)           On 23 January 2016, Dr Rizvi filed his self-assessment tax return (�SATR�) for the year ended 5 April 2015 (�SA 2015�). SA 2015 did not include a claim for EIS relief

(2)           On 5 April 2016, Dr Rizvi subscribed for �300,000 shares in Kerris Films Limited (�Kerris Ltd�).