R (on the application of Phoenix Life Holdings Ltd and other companies) v Revenue and Customs Commissioners

Value added tax – Input tax. The defendant Revenue and Customs Commissioners' (HMRC) decision, upholding its rejection of a claim for repayment of significant amounts of under-recovered VAT input tax made exactly ten years earlier, was so outrageous in its defiance of logic or of accepted moral standards that no sensible person who had applied his mind to the question to be decided could have arrived at it. Accordingly, the Administrative Court quashed the decision and ordered HMRC to pay the claim (to the extent its quantum had been accepted).

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