Some years ago, the then Inland Revenue, acting on the authority of a warrant under TMA 1970, s 20C (see A6.313) carried out a search of several premises and removed a large number of documents. The Court of Appeal held that the raid was illegal and ordered the return of the documents subject to an undertaking that, if their decision was reversed by the House of Lords, all the documents would be handed back to the Revenue. Subsequently, the House of Lords did reverse the decision1, but the taxpayer failed to return five large desk diaries,
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