Queen’s Bench Division (Crown Office List).

[The appeal against this decision is reported at [1996] BTC 183.]

Macpherson of Cluny J.

Judgment delivered 29 July 1994.

Corporation tax – Loss relief – Relief not formally claimed within two years of end of relevant accounting period – Late claims accepted by Revenue over a number of years – Whether Revenue’s refusal to allow claims out of time unfair – Whether applicants could rely on course of dealing to expect that late claims would be accepted – Income and Corporation Taxes Act 1970, s. 177(2), (10) (replaced by s. 393(2), (11) of the 1988 Act).

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