Double Jeopardy in Tax Matters

“The Tribunal further notes that for the first assessment of the same tax period , December 2016,that is the subject of the current appeal, the Respondent closed off the matter and issued a tax decision based on an audit that it undertook .The Tribunal therefore believes that there must have been sufficient documentation provided by the Appellant and reviewed by the Respondent in arriving at its initial final decision dated 20^th December 2018.Due to the foregoing, the Tribunal is clear that the Respondent’s actions, in closing this matter in 2018 in the manner it did , created a legitimate expectation which the Appellant relied on in establishing that any tax issue relating to the tax period December 2016 was fully audited and settled. In this regard, the Tribunal has also confirmed from the pleadings that the Appellant settled the taxes demanded by the Respondent in its Objection Decision without further ado”