General provisions relating to objections and appeals
(1) In any proceedings under this Part, the burden shall be on the taxpayer to prove that a tax decision is incorrect.(2) An appeal to the High Court or to the Court of Appeal shall be on a question of law only.
(3) In an appeal by a taxpayer to the Tribunal, High Court or Court of Appeal in relation to an appealable decision, the taxpayer shall rely only on the grounds stated in the objection to which the decision relates unless the Tribunal or Court allows the person to add new grounds.
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