15 Jun 2007
WIRE SUPPLIES LTD, SLIOC ENTERPRISES LTD, J.J. MCDOUGALL, L.L. MCDOUGALL AND J.U. MCDOUGALL V COMMISSIONER OF INLAND REVENUE CA CA206/05
- Citation
- openlaw-483e8390_8f0f_4fd3_a255_3fda4e2da75c.pdf
- Court
- Court of Appeal
All appeals dismissed. Court held Track B reconstructions were lawful exercises of the Commissioner's s99 powers, intelligibility challenges failed (Hyslop), switching assessment 'tracks' to target affected parties including more solvent payers was not an abuse, evidence of later Track C assessments did not render TRA decisions on Track B erroneous where those matters were already case stated (BASF principle applied), s25(2) certificates provided sufficient evidential basis to lift the time bar, and appellants failed to show prejudice from any alleged privilege waiver or procedural defect.