Queen’s Bench Division.

[The appeal against this decision is reported at [1991] BTC 268.]

Judgment delivered 12 July 1988.

Income tax – Interest on money paid under unauthorised demand for tax – Taxpayer paid sum demanded under regulations pending outcome of judicial review proceedings – Regulations held to be ultra vires – Revenue repaid sum with interest from date of judgment – Whether taxpayer entitled to interest from date of payment – Supreme Court Act 1981, sec. 35A.

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