The High Court (Administrative Division) has considered a claim brought by a taxpayer concerning the question of whether or not correspondence from HMRC gave rise to a legitimate expectation, and if it did whether HMRC resiled from it. The issue turned on the time limits contained within section 9ZA of the Taxes Management Act 1970, concerning the deadline to file an amended return. This is a somewhat novel issue as there are no specific authorities considering this point. In dismissing the taxpayer’s claim, the High Court held that no legitimate expectation had been created, and thus HMRC had not resiled from the same. Dilpreet K. Dhanoa appeared on behalf of the Revenue. A copy of the judgment can be found here: https://www.bailii.org/ew/cases/EWHC/Admin/2024/3014.html
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