Chancery Division.

[The appeal against this decision is reported at [1997] BTC 619.]

Lightman J.

Judgment delivered 18 April 1996.

Corporation tax – Capital allowances – Full first-year allowances withdrawn from 13 March 1984 – Company took over privatised Royal Ordnance Factories in 1984 assuming liabilities including benefit and burden of existing contracts made in 1983 – Contracts refinanced by leasing arrangements – Whether full first-year allowance available by reference to original 1983 contracts – Ordnance Factories and Military Services Act 1984, Sch. 1, para. 4(2); Finance Act 1984, s. 58, Sch. 12, para.4(2).

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