Corporate Enterprises Ltd v Commissioner of Inland Revenue - [2021] 2 NZLR 453

Statutes — Interpretation — Whether appeal rights excluded — Taxation Review Authority rejected claims for goods and services tax refunds — Commissioner of Inland Revenue upheld TRA decisions — Whether exceptional circumstances for late filing of notices of claim — Whether appellants had right of appeal — When confusion between statutes earliest statute prevails — In alternative, whether TRA decision could be subject to judicial review — Exceptional circumstances — Challenge — Tax Administration Act 1994 ss 89AC, 89K, 138B, 138C, 138E and 138S.