Hadee Engineering Co Ltd & Others v The Commissioners for HM Revenue & Customs [2022] UKUT 00084 (TCC)
Upper Tribunal Tax and Chancery decision of Mr Justice Marcus Smith and Judge Jonathan Richards on 17 March 2022
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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