Llandovery Investments Limited v The Commissioner of Taxpayer Appeals

Revenue Law: Taxpayer submitting returns and audited accounts and tax computation showing tax due, but not paying tax in mistaken belief that it was an "Approved agricultural enterprise". Revenue raises assessment based upon accounts submitted; taxpayer purports to submit new un-audited accounts and returns; rejected by Commissioner; previous assessment subject of decision by Commissioner Taxpayer Audit and Assessment; confirmed on appeal to Commissioner Taxpayer Appeals; whether Commissioner wrong in law, whether assessment valid; whether assessment and decision in breach of Assessment provisions of the Income Tax Act as amended