3 Jun 2008
THE COMMISSIONER OF INLAND REVENUE V BNZ INVESTMENTS LIMITED AND ORS CA CA65/2008
- Citation
- openlaw-20b85f8c_098e_4c87_bbf2_2388faa25247.pdf
- Court
- Court of Appeal
Discovery of other banks' private rulings and internal preliminary papers was not necessary or relevant to the Court's s138P rehearing of BNZ's transactions because the Court must assess the purpose and effect of BNZ's transactions independently; the Commissioner’s reasons on other rulings do not operate as admissions nor bind other cases; TAA secrecy and Rule 300 require a conservative, necessity-based limit on discovery; accordingly the High Court's discovery orders were quashed.