Stephen Oliver QC, Dr David Williams.

Decision released 24 March 2003.

Corporation tax – Schedule D – Trading profits – Moneys mistakenly paid to trader – Appellants supplied advertising facilities to customers – Customers mistakenly paid more than invoiced amounts – Overpaid amounts accounted for by appellants as ‘creditors’ but after two years transferred to profit and loss account as exceptional items – Whether overpayments constituted trading receipts accruing or arising from trade for tax purposes.

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