A contractual promise by the executive government to reimburse a taxpayer for tax paid, or to compensate for failure to procure legislative amendments reducing tax liability, is void as an unlawful dispensation from the obligation to pay tax imposed by statute. The distinction between exempting from tax and promising to repay tax elevates form over substance and does not save the promise. A promise by the executive to procure legislative amendments is unenforceable because the executive cannot bind Parliament to legislate. A general statutory power to sell government assets does not authorise the executive to promise tax reimbursement as a term of sale.
The full text is available to signed-in members, including the 8 later cases that cite this judgment.
1 of the 8 citing cases carry a classified treatment. How each court treated it is available to signed-in members.