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Kilmarnock Equitable Co-operative Society Ltd v Inland Revenue Commissioners: SCS 16 Feb 1966

Income Tax, Schedule D – Profits Tax – Capital allowances – Industrial building or structure – Building for screening and packing coal – Whether coal subjected to a process – Whether building used for purpose ancillary to a retail shop – Income Tax Act, 1952 (15 and 16 Geo. VI and 1 Eliz. II, c. … Continue reading Kilmarnock Equitable Co-operative Society Ltd v Inland Revenue Commissioners: SCS 16 Feb 1966

Saxone Lilley and Skinner (Holdings) Ltd v Commissioner of Inland Revenue: HL 1967

The taxpayer company was the parent company of a group of subsidiaries, one of which traded as the manufacturer and retailer of shoes. The others either manufactured or sold shoes. The company built a warehouse which was let to a warehousing subsidiary (Jacksons Limited). Parts of the warehouse were used to store shoes from the … Continue reading Saxone Lilley and Skinner (Holdings) Ltd v Commissioner of Inland Revenue: HL 1967

Kilmarnock Equitable Co-operative Society Ltd v Inland Revenue Commissioners: SCS 1966

References: (1966) 42 TC 675 Coram: Lord Clyde, Lord Guthrie A co-operative society carried on business as general merchants. Its objects included manufacturing of all kinds. A substantial part of its business was the sale of coal in 1cwt bags and in bulk, distributed by lorry from the society’s coal yard or depot. It also … Continue reading Kilmarnock Equitable Co-operative Society Ltd v Inland Revenue Commissioners: SCS 1966

Ridge Securities Ltd v Inland Revenue Commissions: ChD 1964

The taxpayer companies had purported to pay interest on debentures, but these payments were ultra vires and void. Held: The court upheld the Special Commissioners’ disallowance of payments of interest ‘grotesquely out of proportion to the principal amounts secured’ as not being interest within the meaning of section 169. The sums could not accordingly be … Continue reading Ridge Securities Ltd v Inland Revenue Commissions: ChD 1964

Inland Revenue Commissioners v Saxone Lilley and Skinner (Holdings) Ltd: HL 16 Feb 1967

Income tax, Schedule D – Capital allowances – Industrial building or structure – Warehouse used for storing goods delivered to purchasers together with some goods not so delivered – Income Tax Act 1952 (15 and 16 Geo. 6 and 1 Eliz. 2, c. 10), 271. [1967] UKHL TC – 44 – 122, 1967 SC (HL) … Continue reading Inland Revenue Commissioners v Saxone Lilley and Skinner (Holdings) Ltd: HL 16 Feb 1967