5 Dec 2006
THE COMMISSIONER OF INLAND REVENUE v. COMMON EMPIRE LTD
- Citation
- THE COMMISSIONER OF INLAND REVENUE v. COMMON EMPIRE LTD
- Court
- Court of Appeal
- Case number
- CACV83/2006
A statement of loss issued by the Commissioner is an administrative document and not an 'assessment' within the meaning of the Inland Revenue Ordinance; therefore the six year bar under section 60 applicable to assessments does not prevent the Commissioner from revising statements of loss and treating losses as not established when later computing taxable profits, and taxpayers must be able to prove losses when seeking to carry them forward even after six years.