Commentary on Sections Overview Overview Section 705: Appeals against counteraction notices
2102.This section is concerned with appeals against counteraction notices. It is based on section 705(1) and(5) of ICTA.
2103.Section 705(5) of ICTA gives the Special Commissioners the power not only to vary or quash an assessment but also, implicitly, to affirm it: see Browne-Wilkinson J in Anysz v CIR (1977), 53 TC 601 ChD at page 630(4). Subsection (3) makes this implication explicit, and similarly makes it explicit that the Special Commissioners have the power to affirm a counteraction notice.