4 Feb 2008
BNZ INVESTMENTS LIMITED (AND OTHERS) V THE COMMISSIONER OF INLAND REVENUE HC WN CIV 2004-485-1059
- Citation
- openlaw-3139c689_fd6e_48fb_a9a1_f79eee85d37c.pdf
- Court
- High Court
Paragraphs 11.2 and 12.1 of the amended statement of claim are struck out because they improperly seek to set aside the amended assessments by attacking the Commissioner's reasons (raising matters akin to judicial review, legitimate expectation or consistency) which are irrelevant to the question whether the assessments correctly quantify tax liability; however, pleadings and discovery that rely on prior favourable private binding rulings and documents the Commissioner took into account in granting rulings are relevant and, to the extent sought, discoverable; discovery of documents underlying…