“…d Burrows in Tinkler v HMRC [2021] UKSC 39, [2022] AC 886 at [45], approving with minor modifications Briggs J’s summary of principle in HMRC v Benchdollar Ltd [2009] EWHC 1310 (Ch), [2010] 1 All ER 174. I have made the modification in the italicised part of the quotation that follows:…”
“…d Burrows in Tinkler v HMRC [2021] UKSC 39, [2022] AC 886 at [45], approving with minor modifications Briggs J’s summary of principle in HMRC v Benchdollar Ltd [2009] EWHC 1310 (Ch); [2010] 1 All ER 174. I have made the modification in the italicised part of the quotation that follows:…”
“…Lord Steyn’s principles were elaborated upon by Briggs J in HM Revenue v. Benchdollar [2009] EWHC 1310 (Ch) (“Benchdollar”), in the context of an estoppel by convention arising out of non-contractual dealings:…”
“…Briggs J in HMRC v Benchdollar Limited and Ors [2009] EWHC 1310 (Ch), [2010] 1 All ER 174 at [52]. This summary was approved by the Court of Appeal in Blindley…”