“…he tax code applies to the taxpayer’s case I do not consider that the civil courts are barred from dealing with that dispute: see HMRC v Cotter [2013] UKSC 69, [2013] 1 WLR 3514 at [32].”…”
“… construction which have already led to three cases reaching the Supreme Court: the first in time was Revenue andCustoms Commissioners v Cotter [2013] UKSC 69, [2013] 1 WLR 3514 (Cotter); the second was De Silva;and the most recent, in April…”
“…whether or not a claim is included in a return. This question was considered by the Supreme Court in Revenue and Customs Commissioners v Cotter [2013] UKSC 69; [2013] 1 WLR 3514 (“Cotter”), where it held that a return did not include the entirety of the information set out in the return, but only that information which was submitted fo…”