England and Wales Court of Appeal (Civil Division) Decisions

Corporation tax—Losses—Relief Time-limit - Substantive Fairness - Judicial review—Claims for relief against other profits of same period—Claims refused—Whether estimated figures delivered within two-year time-limit constituted claims—Express claims made after expiry of time-limit—Previous late claims admitted without question—Whether Revenue wrongly refused claims—Income and Corporation Taxes Act 1970, s 177(2) and {10), Taxes Management Act 1970, s 1, Income and Corporation Taxes Act 1988, ss 393(2) and (11) and 393A(10).

Appeal [1996] EWCA Civ 68_TC_205 found on Page 16