In Karim Makji v HMRC [2014] TC04014 a taxpayer's attempts to limit an enquiry were not enough to allow an appeal against a schedule 36 information notice. 

The taxpayer made significant remittances to the UK in 2007-08 and HMRC issued an information notice under Sch 36 FA2008 to obtain copies of the taxpayer’s bank account for that year. The information notice was specifically limited to those accounts from which any remittances to the UK were made from during the tax year in question.

The Appellant argued that these statements alone were unlikely to be sufficient to trace the sums in the account back to the source claimed by the him, and that these statements and the requested “analysis of the contents of the account(s) for the year” were likely to lead to further requests by HMRC for additional documents and information.

The tribunal found that although this may mean that the information notice is likely to make HMRC’s enquiries even more troublesome from the Appellant’s point of view, this of itself does not mean that the requested information is not “reasonably required” for purposes of paragraph 1 of Schedule 36.

There were no serious grounds for appeal here. This was not a "fishing expedition" as HMRC was only looking for information in respect of a year under enquiry.