[2005] CSOH 135.

Court of Session, Outer House.

Lord Drummond Young.

Judgment delivered 18 October 2005.

Income tax – Relief – Foreign earnings deduction – Assessment – Appeal out of time – Error or mistake relief – Reasonable excuse for not bringing appeals within time-limit – General commissioners granting taxpayer’s application for late appeals – Revenue seeking judicial review – Whether commissioners’ decision unreasonable – Taxes Management Act 1970, s. 33, 49(1), 54.

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