Court of Appeal Wellington
26 February; 3 April 1990
Cooke P, Richardson and Hardie Boys JJ
26 February; 3 April 1990
Cooke P, Richardson and Hardie Boys JJ
Income tax — Assessments — Time limit — For 1976 and 1977 income years Commissioner issued notices to taxpayer showing no tax payable because of losses carried forward — More than four years later Commissioner purported to make assessments of income tax for the 1976 and 1977 years — Whether notices issued by Commissioner were "assessments" — Whether Commissioner was subsequently barred from making assessments for those years — Income Tax Act 1976, ss 19 and 25.
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