Court of Appeal (Civil Division).

[The appeal against this decision is reported at [1993] BTC 147.]

Glidewell, Beldam and Nolan L JJ.

Judgment delivered 6 February 1992.

Capital gains tax – Indexation relief – Assets acquired before 1965 – Straight-line time-apportionment of gain – Whether chargeable gain to be computed before or after applying indexation relief – Whether indexation relief calculated by reference to chargeable gain or total gain – Capital Gains Tax Act 1979, Sch. 5, para. 11; Finance Act 1982, sec. 86(2), (4) (as amended) and modified by Finance Act 1985, sec. 68, Sch. 19.

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