England and Wales Case Law

Zafari, R (On the Application Of) v Commissioners for His Majesty's Revenue and Customs

Zafari, R (On the Application Of) v Commissioners for His Majesty's Revenue and Customs [2024] EWHC 3014 (Admin) (28 November 2024)

The High Court rejected a judicial review challenge to HMRC’s refusal to accept late amended self-assessment returns, finding no clear legitimate expectation arose.

• Legitimate expectation
• Discretionary powers of hmrc
• Amendment of tax returns
• Statutory time limits
• Judicial review procedure
• Legitimate-expectation

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Nigel Barklem v The Commissioners for HMRC

The High Court struck out a taxpayer’s Part 7 claim challenging HMRC’s partner-level amendments under s.28B TMA and held the dispute should have been brought by judicial review.

• Partnership tax schemes
• Abuse of process
• Declaratory relief
• Closure notices
• Summary judgment
• Judicial review

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Amrolia, R (on the application of) v HM Revenue & Customs

The High Court held that HMRC validly amended partnership loss claims and could recover overpaid tax and earlier-year repayments under section 59B(5) TMA.

• Self-assessment tax returns
• Loss relief
• Amendment of tax returns
• Judicial review
• Tax repayment and recovery
• Tax-law

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Amrolia, R (on the application of) v HM Revenue & Customs

Amrolia, R (on the application of) v HM Revenue & Customs [2018] EWHC 1688 (Admin) (04 July 2018)

The High Court upheld HMRC’s amendments to self-assessment returns after a partnership loss enquiry, confirming recovery of overpaid tax under section 59B(5) TMA.

• Self-assessment tax returns
• Partnership losses
• Tax relief claims
• Amendment of tax returns
• Judicial review of hmrc decisions
• Self-assessment-tax

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