Chancery Division.

Judgment delivered 12 November 1987.

Income tax – Assessment out of time – Fraud or wilful default – Wilful default on the part of accountants who submitted return on behalf of the taxpayer containing misleading information – Taxpayer himself unaware that information was misleading and not guilty of wilful default – Whether assessment could be made out of time – Taxes Management Act 1970, sec. 36.

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