SSE built a hydroelectric scheme in Scotland at a cost of £300m, including rectification works. The company claimed capital allowances amounting to £260m on items of plant under CAA 2001, s 11. HMRC accepted only £34m and refused the rest on the basis they were disqualified under s 21 and s 22. The First-tier Tribunal allowed the taxpayer’s appeal. After the Upper Tribunal dismissed its appeal, HMRC took the case to the Court of Appeal.
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