Special Commissioners of Income Tax 19 July 2007, Spc 00619 (Tower Mcashback LLP1 Tower Mcashback LLP2 v Her Majesty's Revenue & Customs)

Spc00619 Capital expenditure on software - whether HMRC can raise additional contentions in an appeal beyond those indicated in the Closure Notice - whether expenditure was incurred pursuant to an unconditional contract - whether the expenditure paid 10 months after the date of the contract was still paid under a contract that required payment within a four month period, or whether the eventual