17 Mar 2023
CLEAN WATER LTD v. COMMISSIONER OF INLAND REVENUE
- Citation
- [2023] HKCFI 744
- Court
- Court of First Instance
- Case number
- HCIA2/2023
The application for leave to appeal was dismissed because the proposed grounds did not raise proper questions of law with a reasonable prospect of success: the Board correctly applied settled legal principles (taxpayer's burden under s68(4) IRO and the civil standard of proof; the what/where test for source of profits), its conclusions that there was insufficient evidence to identify the profit‑producing operations and their location were factual findings not open to challenge on the point-of-law gateway, and its refusal to admit late documents was a proper exercise of its procedural discreti…