“…hat in section 46(1). But I am, I think, following the general guidance as to the application of deeming provisions given by Peter Gibson LJ in Marshall v Kerr [1993] STC 360, 365–366, approved by this House on appeal [1995] AC 148,…”
“… deeming provisions are to be approached. In that case, Lord Browne-Wilkinson endorsed this passage from the judgment of Peter Gibson J in the Court of Appeal ([1993] STC 360, at 366):…”