Adjudication Support
Drafting, documentation and appearance before the adjudicating authority, so that your case is complete at the stage where the record is built.
Adjudication is the stage at which the officer decides a show cause notice after considering your written reply and the personal hearing. It produces the order-in-original that fixes tax, interest and penalty. Because appellate authorities largely work from the record created here, the submissions, documents and case law placed at adjudication determine how much room the appeal will have later.
What our adjudication support covers
Putting the whole case on record while the record is still open.
- Preparing written submissions arranged issue by issue against the allegations in the notice
- Compiling a paper book of contracts, invoices, ledgers, returns and reconciliations
- Appearing at personal hearings and recording the submissions made
- Seeking cross-examination where the demand rests on third party statements
- Filing further submissions after the hearing where the authority permits
- Reviewing the order-in-original and advising on appeal, rectification or payment
What the adjudicating authority works from
The record that decides the order, and every appeal after it.
Paper Book
An indexed compilation of every document relied on, arranged so that each submission points to the page that supports it.
Personal Hearing
The opportunity to explain the case orally, with adjournments limited to the number prescribed and granted only for recorded reasons.
Relied-Upon Documents
Documents and statements the department relies on must be supplied to you, and where they are not, that itself is a ground.
Order-in-Original Review
Reading the order against the notice and the submissions, to identify what was not dealt with and what can be rectified.
Our process
From initial consultation to completion.
Case Preparation
Building the issue list, the evidence for each issue and the authorities that support the position.
Submission Filing
Filing written submissions and the paper book ahead of the hearing rather than at it.
Hearing Appearance
Appearing before the authority, answering questions and placing anything further that is called for.
Post-Order Advice
Assessing the order for appeal, rectification or acceptance, with the limitation dates fixed in writing.
Why the first record decides the last appeal
What sets our approach apart.
Evidence is hard to introduce later
Appellate authorities admit additional evidence only in limited circumstances, so a document not filed at adjudication may never be looked at.
Silence on an issue is read against you
An allegation the order records as unrebutted becomes the starting point of the appellate hearing.
Adjournments are limited
The number of adjournments available at adjudication is capped, so preparation cannot be deferred indefinitely.
Adjudication questions answered
What people ask before engaging us.
You may also need
Other areas we regularly help clients with.
Hearing date fixed and submissions not ready?
We will build the paper book, draft the submissions and appear with you.