A second set of discovery assessments were not validly issued, as an earlier set of discovery assessments relating to the same discovery had been issued, but HMRC withdrew its appeal against them due to technical flaws, and the First-tier Tribunal had allowed the appellant’s appeal. 

HM Revenue and Customs (HMRC) received information alleging that the appellant’s employer (DAL) had been paying off-payroll cash bonuses to its employees and providing them with prestige company cars without declaring the provision of benefits for income tax and National Insurance contributions purposes. Consequently, HMRC visited DAL’s premises in September 2014. HMRC was provided with a spreadsheet showing cars allocated to individual employees, including a Range Rover Sport allocated to the appellant.