Lemmington Holdings Ltd v Commissioner of Inland Revenue - [1984] 2 NZLR 214

Income tax — Application for review — Jurisdiction — Duty on Commissioner to act fairly at pre-assessment stage — Commissioner had withdrawn approval of a plan under which the company's investors would be able to claim that as manufacturers they had sustained losses which they could offset against other current income — Before any assessments had been issued against individual investors, company and an investor sought judicial review of Commissioner's decisions — Whether Commissioner had a duty to act fairly — Whether he was in breach of such a duty — Whether his decisions were based on wrong or irrelevant grounds — Judicature Amendment Act 1972, s 4.