Chancery Division.

Judgment delivered 21 January 1982.

Capital duty – Shares issued partly-paid before date when capital duty introduced – Call made after date on which duty imposed – Whether capital duty chargeable on payment of such call – Finance Act 1973 – sec. 47, Sch. 19, para. 1(b)

  This was an appeal by the taxpayer against findings of the Commissioners that a payment received pursuant to a call made on partly-paid shares was an increase in the taxpayer’s capital by a contribution of assets and was chargeable to capital duty.

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