R (on the application of PML Accounting Ltd) v Revenue and Customs Commissioners

Income tax – Taxpayer notice. The judge had been correct to decide that the defendant Revenue and Customs Commissioners (HMRC) had been entitled to argue that all questions of validity of a taxpayer notice had been determined by an agreement under s 54 of the Taxes Management Act 1970 and could not be revisited by the claimant. Accordingly, it dismissed the claimant's appeal against the judge's decision, dismissing its application for judicial review of HMRC's refusal to provide or delete any information, analysis and work product derived from the material provided pursuant to the notice.

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