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HMRC internal manual

Self Assessment: the legal framework

HM Revenue & Customs
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Enquiries into Tax Returns: appeals

The normal appeal procedures apply in respect of any appeal against an HMRC assessment (eg Sections 31, 50, 55 etc).

Appeals that relevant conditions for discovery assessment do not apply

Section 29(8)

Any objection that the conditions at Section 29(4) or (5) do not apply (see the last paragraph under General circumstances in which discovery assessments can be made in SALF409) must be made by an appeal against the assessment.