4 Dec 2009
THE COMMISSIONER OF INLAND REVENUE V CONTRACT PACIFIC LIMITED CA CA759/2008
- Citation
- openlaw-b3efaf94_19f6_404e_bd2f_1d95a90546f0.pdf
- Court
- Court of Appeal
The Commissioner validly gave notice of intention to investigate within the 15 working day period in s46(5); s46(2)(a) and s46(2)(b) are alternative and distinct, so where an investigation is properly commenced further information requests made in the course of that investigation are not constrained by the s46(4) time limits, and therefore the Commissioner was entitled to withhold the refund and the appeal is allowed.