Ditchfield (H.M. Inspector of Taxes) v Trustees of the Orwell Share Settlement.  BTC 39
Judgment delivered 6 November 1981.
Income tax – Whether gain of an income nature – Whether excess received on discharge of promissory note a ‘discount’ chargeable under Case III of Sch. D – Whether a discounting transaction – Income and Corporation Taxes Act 1970 – sec. 108(1)(b); 109.
This was an appeal by the Crown from the decision of the Special Commissioners that a gain made by the taxpayers was not an annual profit or gain chargeable to income tax.