asked Revenue if certain investments would be taxed as capital or income.
said capital, but later taxed assets as income.
must fail if representation in breach of Revenue’s statutory duty.
representation did not breach Rev’s statutory duty – merely acting in pursuance
of its proper managerial discretion.
such circumstances, Revenue could not withdraw from representation if this
would cause substantial unfairness to applicant and if conditions for relying
upon any such representation were present.
Applicant should give full details of transaction on which Revenue’s ruling
Applicant should make it apparent that it was seeking considered ruling which
it intended to rely upon.
Ruling must be clear and unambiguous.