Law of estoppel does not arise in adjudication of appeal from Revenue Appeal Commissioners

Revenue - appeal by way of case stated - Revenue assessments – issues for determination - the facts not in dispute – whether there is any rule of law that precludes the taking of any steps in a Revenue audit whilst a Revenue enquiry is in being – statutory interpretation - nothing that precludes, as a matter of law, the resumption of the audit - no rule of law within the question set out in the case stated to prevent any steps taken in the course of the Revenue audit whilst a Revenue enquiry was in being – entitlement of the court to hold that s. 955(2) applies on the facts of this case - whether any rule of law required the revenue, prior from taking steps in respect of their audit to furnish effective notice to the appellant that the enquiry was no longer proceeding – whether the audit would only be deemed to take effect once effective notice was given – Circuit Court held notification that the audit was continuing, brought with it the implication that the Revenue enquiry had come to an end - no rule of law that that the revenue audit was not deemed to take effect prior to effective notice being given that the enquiry was not proceeding - three prompted disclosures were made - does not come within the statutory definition of “has made in the return a full and true disclosure of all material facts necessary for the making of an assessment for the chargeable period” – provision applies and the four year limit is not available – estoppel - whether the doctrine of estoppel is applicable to the Circuit Court in circumstances of a Revenue appeal - scope of jurisdiction of the Appeal Commissioners and the Circuit Court on appeal - revenue law has no equity - law of estoppel does not arise in the adjudication of the Circuit Court, in circumstances of an appeal from the Appeal Commissioners - does not arise in the calculation or computation of any assessment and in the interpretation of the statute as to the validity of the assessment - issue as to whether this appellant is entitled to equitable relief arising upon that adjudication is not a matter for adjudication by a judge of the Circuit Court, upon an appeal from the Appeal Commissioners - initial error in the statement of an amount assessed and whether that precludes the establishment at hearing before the Appeal Commissioners or the Revenue Commissioners of a different amount - relevant assessment was corrected and the position was notified to the appellant taxpayer - no issue can have arisen –