V1.273 Administrative decisions

HMRC are given wide powers on a number of matters which necessarily involve an element of discretion, eg whether or not to allow a body corporate to separately register its divisions1.

In certain cases there are apparent restrictions on the power of HMRC, in that they are to act in a certain way only where it appears to them necessary to do so for the protection of the revenue2. In other cases the wording is more general, eg “if the Commissioners see fit”3, “if … they4 think fit”, “as appear to the Commissioners necessary or expedient”5, and “as

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