Dr Banerjee – a big up

And to her counsel and solicitors, who acted pro bono.

In HMRC v Banerjee [2009] EWHC 62 (Ch), the High Court has upheld a registrar’s claims that her training expenses were incurred wholly, exclusively and necessarily in the performance of the duties of her employment, under what is now ITEPA 2003, s.336(1) (previously ICTA 1988, s.198(1)). The judgment will receive plenty of attention, and the Revenue must now be having second thoughts over whether it was a good idea for them to take the appeal when they had already succeeded, albeit with some luck on their side, in the earlier case, displaying similar facts, of HMRC v Decadt [2007] EWHC 1659 (Ch).