Procter & Gamble Ltd v Taylerson (HM Inspector of Taxes).  BTC 462
Court of Appeal (Civil Division).
Dillon, Balcombe and Butler-Sloss L JJ.
Judgment delivered 4 July 1990.
Corporation tax – Advance corporation tax – Surplus over mainstream tax – Provisional claim made within time limit to carry back surplus to previous accounting period – Claim subsequently agreed and amount set off against previous year’s profits – Losses subsequently incurred were carried back increasing surplus – Whether original claim to carry back surplus might be adjusted to include increased losses – Finance Act 1972, sec. 85(3) (now Income and Corporation Taxes Act 1988, sec. 239(5)).