Privy Council.

Lord Nicholls of Birkenhead, Lord Browne-Wilkinson, Lord Steyn, Lord Hoffmann, Sir Kenneth Keith.

Judgment delivered 4 December 2001.

Income tax – Assessment – Gross profits – Insurance – New Zealand life insurance companies – Whether interest on overdue premiums taxable as investment income – Income Tax Act 1976, s. 204.

  This was an appeal by the New Zealand Commissioner of Inland Revenue from a decision of the Court of Appeal of New Zealand allowing the taxpayer’s appeal against income tax assessments.

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