HM Revenue & Customs cannot make discovery assessments
during an enquiry.
A discovery assessment can only be made when an enquiry is
settled and new information comes to light or where there has been
no enquiry and we find that a land transaction return is wrong and
the time limit for enquiry has ended. Discovery assessments will in
practice be very rare.
If during the course of the enquiry the Stamp Office believes
a self-assessment is insufficient and there is likely to be a loss
of tax they can amend the self-assessment underFA03/SCH10/PARA17.
This is known as a jeopardy amendment.