Privy Council Wellington
27 April; 29 October 1998
Lord Browne-Wilkinson, Lord Nolan, Lord Hope of Craighead, Lord Clyde and Sir John Balcombe
27 April; 29 October 1998
Lord Browne-Wilkinson, Lord Nolan, Lord Hope of Craighead, Lord Clyde and Sir John Balcombe
Revenue — Income tax — Assessment — Whether liability imposed by statute or by assessment made by Commissioner — Nature of assessment — Machinery for giving effect to statutory liability — Joint assessment of companies — Effect in objection proceedings of assessment not made in accordance with statute — Income Tax Act 1976, s 191(5), (7), (7A) and (8).
Revenue — Income tax — Assessment — Unauthorised practice — Technical Rulings Manual dispensing with statutory requirement — Whether tax liability affected by unauthorised practice — Income Tax Act 1976, s 191(5A) and (8).
Revenue — Income tax — Annual tax — Tax year — Operation of statutory provision in force before during and after tax year but disqualifying taxpayer from deduction by reason of events occurring after end of tax year — Income Tax Act 1976, ss 188(7) and 191(7A).
Revenue — Income tax — Assessment — Joint assessment of group of companies — Liability of individual companies where joint assessment made — Income Tax Act 1976, s 191(5), (7), (7A) and (8).
Statutes — Construction — Whether later statute may be invoked to construe earlier unambiguous statute — Income Tax Act 1976, s 191(8).
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