[2005] EWHC 1043 (Admin).

Queen’s Bench Division (Administrative Court).

Lightman J.

Judgment delivered 25 May 2005.

Value added tax – Overpayment – Repayment – Interest – Three-year time limit – Revenue concession – No time limit for correcting error consisting of simple duplication of output tax — Revenue refusing to apply concession – Customs refusing payment of interest on overpaid VAT – Taxpayer applying for judicial review of both decisions – Whether Revenue entitled not to apply concession on facts alleged by taxpayer – Value Added Tax Act 1994, s. 80(4).

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