Samarkand Film Partnership No 3 & Ors v Revenue And Customs [2015] UKUT 211 (TCC) (29 April 2015)
INCOME TAX -“partnerships engaging in sale and leaseback of films and partners claiming losses under film acquisition relief provisions ss130-140 ITTOIA -“ whether trading - held no - appeal dismissed -“ if trading, whether business carried on on a commercial basis -“ amount of acquisition expenditure incurred in respect of original master version of The Queen -“ whether partnership loss rules s118ZE ICTA restrict use of any loss -“ whether Proteus-™s relevant period less than 12 months s138 of ITTOIA -“ whether expenditure of a revenue nature JUDICIAL REVIEW -“ whether claimants had legitimate expectation derived from HMRC-™s Business Income Manual -“ whether claimants had legitimate expectation derived from HMRC-™s settled practice -“ whether HMRC acted with conspicuous unfairness
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