Queen’s Bench Division.

[The appeal against this decision is reported at [1984] BTC 353.]

Judgment delivered 24 February 1983.

Income tax – Tax avoidance – Agreement between taxpayer and Revenue – Whether Revenue exercised a discretion or a duty to seek the information it required – Whether unfair of Revenue to seek to exercise powers – Income and Corporation Taxes Act 1970, sec. 460; 465.

  This was an application for judicial review against the Inland Revenue Commissioners in respect of action taken by the Revenue under tax avoidance provisions of Pt. XVII of the Income and Corporation Taxes Act 1970.

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