If HMRC discover that any group relief given (for current year losses or brought forward losses) is or has become excessive, they may make an assessment for the amount which in their opinion ought to be charged1. This power is without prejudice to the making of a discovery assessment (A6.705) and to the making of any adjustments by way of discharge or repayment of tax or otherwise as may be necessary where a claimant company has obtained too much relief or a surrendering company has foregone relief in respect of a corresponding amount2.
The normal time limits apply to the issue of such assessments, unless the assessment is made because the claimant company has failed to amend its tax
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