Reassessment based on inapplicable share-transaction information fails when disclosed intraday profit does not match the recorded reopening reasons.

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....Reassessment based on inapplicable information is examined where recorded reasons allege manipulated share transactions involving capital gains or losses, but the taxpayer's actual transaction was an intraday share trade with disclosed business profit. The notes state that, where the alleged transactions do not exist in the taxpayer's case and the disclosed profit remains below the reopening threshold cited in the reasons, the factual foundation for reopening fails. They further note that a Tribunal order quashing such reassessment was not interfered with because no substantial question of law arose from those factual findings.....