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Taxation Administration Act 1953
14ZZKGrounds of objection and burden of proof
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14ZZK Grounds of objection and burden of proof
On an application for review of a reviewable objection decision: (a) the applicant is, unless the ART orders otherwise, limited to the grounds stated in the taxation objection to which the decision relates; and (b) the applicant has the burden of proving: (i) if the taxation decision concerned is an assessment—that the assessment is excessive or otherwise incorrect and what the assessment should have been; or (ii) in any other case—that the taxation decision concerned should not have been made or should have been made differently.