20 Aug 1998
HKSAR v. LAM CHUN SUM, SAMUEL
- Citation
- HKSAR v. LAM CHUN SUM, SAMUEL
- Court
- Court of Appeal
- Case number
- CACC188/1997
Section 51(5) deems a signatory of a tax return to be cognizant of the full contents of the return as presented to the Commissioner including attached schedules; that presumption of knowledge, if unrebutted, shifts the onus under s.82(1)(d) to the defendant to establish reasonable grounds for believing the return true, and failure to do so permits conviction based on circumstantial evidence demonstrating wilful intent to assist tax evasion.