Taxes Consolidation Act, 1997 (Number 39 of 1997)
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959AJ Chargeable persons and other persons: grounds for appeal.
(1) Where an appeal is brought against an assessment or an amended assessment made on a person for any chargeable period, the person shall specify in the notice of appeal—
(a) each amount or matter in the assessment or amended assessment with which the person is aggrieved, and
(b) the grounds in detail of the person’s appeal as respects each such amount or matter.
(2) Where, as respects an amount or matter to which a notice of appeal relates, the notice does not comply with subsection (1), the notice is, in so far as it relates to that amount or matter, invalid and the appeal concerned shall, in so far as it relates to that amount or matter, be deemed not to have been brought.
(3) A person is not entitled to rely on any ground of appeal that is not specified in the notice of appeal unless the Appeal Commissioners, or the judge of the Circuit Court, as the case may be, are or is satisfied that the ground could not reasonably have been stated in the notice.
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959AJ Appeals against time limits for making enquiries and taking actions.
(1)This subsection applies where—
(a) a chargeable person is aggrieved by an enquiry made or an action taken by a Revenue officer under section 959Z for a chargeable period, after the expiry of the period referred to in subsection (3) of that section in respect of the chargeable period, on the grounds that the chargeable person considers that the Revenue officer is precluded from making the enquiry or taking the action by reason of that subsection, and
(b) an assessment has not been made or amended, as the case may be, in respect of the chargeable period on foot of the officer's enquiry or action.
(2) Where subsection (1) applies, the chargeable person may appeal to the Appeal Commissioners, in accordance with section 949I, within the period of 30 days after the date on which the officer makes that enquiry or takes that action.
(3) Where paragraph (a) of subsection (1) applies and an assessment has been made or amended, as the case may be, for the chargeable period referred to in that subsection on foot of a Revenue officer's enquiry or action, a chargeable person may appeal to the Appeal Commissioners under and in accordance with [3]>section 959AF(2)<[3][3]>section 949AF(1)<[3].
(4) Where a chargeable person appeals to the Appeal Commissioners under subsection (2)—
(a) any requirement that there be taken, by the chargeable person (pursuant to the officer's enquiry or action) any action, shall be suspended, and
(b) no further action proposed to be taken by a Revenue officer (pursuant to the officer's enquiry or action) shall be taken,
pending the determination of the Appeal Commissioners on that officer's right to make the enquiry or take the action.
(5) Where, as a result of an appeal to the Appeal Commissioners under subsection (2), the Appeal Commissioners determine that a Revenue officer—
(a) was precluded from making the enquiry or taking the action by reason of section 959Z(3), the chargeable person shall not be required to take any action pursuant to the officer's enquiry or action and the officer shall be prohibited from pursuing his or her enquiry or action, or
(b) was not precluded from making the enquiry or taking the action by reason of section 959Z(3), the officer may continue with his or her enquiry.
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