7 Sept 2004
THE COMMMISSIONER OF INLAND REVENUE v. YAU LAI MAN, AGNES t/a L.M. YAU & CO
- Citation
- THE COMMMISSIONER OF INLAND REVENUE v. YAU LAI MAN, AGNES t/a L.M. YAU & CO
- Court
- Court of First Instance
- Case number
- HCIA3/2004
Computations of loss issued by an assessor do not constitute 'assessments' for purposes of ss60 and 70 of the IRO because an assessment presupposes a positive tax liability; accordingly the 19 January 2001 notices for 1995/96 and 1997/98 were valid (either original or valid additional assessments within s60 and permitted by the s70 proviso) and the Board erred in holding otherwise and in applying the Reasonableness Test absent an agreement; appeal allowed with costs to appellant.