Wilson & Horton Ltd v Commissioner of Inland Revenue - [1996] 1 NZLR 26

Revenue — Goods and services tax — Supply of services — Sales of newspaper advertising space to foreign clients — Services or goods offered by New Zealand residents — Goods situate in New Zealand but not offered by New Zealand residents — Goods situate in New Zealand offered by New Zealand residents — "Image" advertisements where goods or services are sold in New Zealand — Whether all or any of such advertisements should be zero-rated — Meaning of "for and to a person who is not resident in New Zealand" — Goods and Services Tax Act 1985, s 11(2)(e).

Practice and procedure — Appeals to Court of Appeal — Proposed argument in Court of Appeal not raised in High Court — Proposed argument inconsistent with appellant's approach in High Court — Whether leave should be granted to argue new point — Whether Commissioner limited to original basis of assessment.

Statutes — Interpretation — Presumption that every word in a statute to be given meaning — Whether presumption displaced if words used in a tautologous manner — Whether word "for" interchangeable with word "to" in s 8(1)(e) of Goods and Services Tax Act 1985 — Goods and Services Tax Act 1985, s 8(1)(e).