28 Feb 1997
EXTRAMONEY LTD v. COMMISSIONER OF INLAND REVENUE
- Citation
- EXTRAMONEY LTD v. COMMISSIONER OF INLAND REVENUE
- Court
- Court of First Instance
- Case number
- HCIA4/1996
Issue estoppel did not apply because parties and issues differed and the conditions for estoppel were not satisfied; the Board was entitled to treat the High Court judgment as evidence only; the taxpayer failed to discharge the burden under s.70A to prove the assessment was excessive due to an 'error or omission' since the attribution of profits was a deliberate allocation and not an error within s.70A; therefore the Board's decision was not perverse and must stand.