Privy Council.

Lord Templeman, Oliver of Aylmerton. Lord Slynn of Hadley, Lord Woolf and Lord Lloyd of Berwick.

Judgment delivered 19 July 1994.

Profits tax – Hong Kong – Determination of objection by Commissioner of Inland Revenue to be given ‘within a reasonable time’ – Whether provision ‘mandatory’ or ‘directory’ – Whether commissioner had made determination within a reasonable time and if not whether he had jurisdiction to make determination – Whether non-compliance rendered determination ineffective – Inland Revenue Ordinance (Hong Kong) (Cap. 112) s. 64(2).

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