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HMRC internal manual

Business Income Manual

Computing the amount to assess: business changes: a matter of fact

The courts have repeatedly emphasised that questions in this area are ones of fact for the Tribunal. The principles of law are laid down by the courts, but it is for the Tribunal to apply the principles to the facts before them. It will rarely be possible to determine questions simply by comparing the facts with those in decided cases. It is the principles that emerge from the cases that must be applied.

It follows also that a decision of the Tribunal will normally be final unless it can be argued that no person acting judicially and properly instructed as to the relevant law could have come to that decision (Edwards v Bairstow & Harrison [1955] 36TC207).