20 Jun 2006
BARING SECURITIES (HONG KONG) LTD v. THE COMMISSIONER OF INLAND REVENUE
- Citation
- BARING SECURITIES (HONG KONG) LTD v. THE COMMISSIONER OF INLAND REVENUE
- Court
- Court of Appeal
- Case number
- CACV202/2005
The Court allowed the Commissioner's appeal because the trial judge impermissibly substituted his own fact-finding for the Board of Review; given the Board's findings it was open and reasonable for the Board to conclude the Taxpayer had not discharged the burden of proving an offshore source for the disputed profits, and the Board's conclusion was not perverse or unsupported by the evidence.