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First-tier Tribunal (Tax) |
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You are here: BAILII >> Databases >> First-tier Tribunal (Tax) >> Strathedin Properties Ltd & Anor v Revenue & Customs (INCOME TAX/CORPORATION TAX : Profits) [2018] UKFTT 293 (TC) (05 June 2018) URL: http://www.bailii.org/uk/cases/UKFTT/TC/2018/TC06523.html Cite as: [2018] UKFTT 293 (TC)(05 June 2018), [2018] UKFTT 293 (TC)(5 June 2018) |
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| Decision Number: | TC 06523 |
| Appellant: | Strathedin Properties Ltd, Mr Humayun Reza |
| Respondent: | The Commissioners for Her Majesty's Revenue & Customs |
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Chairmen / Special Commissioners: |
Dr Heidi POON |
| Date Of Decision: | 05/06/2018 |
| Main Category: | INCOME TAX/CORPORATION TAX |
| Main Subcategory: | Profits |
| Notes: | INCOME AND CORPORATION TAX - connected parties - sale of property below market value - assessments appealed - valuation being the only ground of appeal - matter referred to Lands Tribunal - agreement on valuation before hearing - whether Consent Order on valuation can be characterised as a s 54 TMA agreement; yes - (a) common intention to reach agreement over a particular matter; (b) agreement in relation to the assessments under appeal; (c) agreement competent to fix quantum of assessments and to dispose of substantive matter under appeal - settlement of appeals ensued within the statutory context of -˜like consequences' ¬-“ application to amend grounds of appeal refused |
