Hadee Engineering Co Ltd & Others v The Commissioners for HM Revenue & Customs [2022] UKUT 00084 (TCC)
| Jurisdiction | UK Non-devolved |
| Judge | Mr Justice Marcus Smith,Judge Jonathan Richards |
| Neutral Citation | [2022] UKUT 00084 (TCC) |
| Subject Matter | 17 March 2022 |
| Court | Upper Tribunal (Tax and Chancery Chamber) |
| Published date | 18 March 2022 |
[2022] UKUT 00084 (TCC)
Appeal number: UT/2021/000037
CORPORATION TAX, CAPITAL GAINS TAX, INCOME TAX – expenditure
allowable under s38(1)(b) of TCGA 1992 – penalties imposed under s95 of TMA 1970
– interaction of s393A of ICTA 1988, paragraphs 58 and 59 of Schedule 18 FA 1998
and Schedule 1A of TMA 1970 in relation to carry back of losses for corporation tax
– appeal dismissed
UPPER TRIBUNAL
(TAX AND CHANCERY CHAMBER)
PETER LOWE (1)
CIVIC ENVIRONMENTAL SYSTEMS LTD (2)
Appellants
-and-
THE COMMISSIONERS FOR HER MAJESTY’S
REVENUE AND CUSTOMS
Respondents
Sitting in public at Rolls Building, 7 Rolls Buildings, Fetter Lane, London EC4A 1NL on
18 February 2022
Michael Firth, instructed by The Independent Tax & Forensic Services LLP for the
Appellants
Charles Bradley, instructed by The General Counsel and Solicitor for Her Majesty’s
Revenue and Customs for the Respondents
TRIBUNAL:
MR JUSTICE MARCUS SMITH
JUDGE JONATHAN RICHARDS
2
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