The taxpayers had attempted to restrict HMRC to the grounds for refusing its capital allowances claim referred to in the closure notice despite the broader grounds for challenge raised during the enquiry. The Court held that while the scope and subject matter of the appeal would be defined by the conclusions stated in the closure notice, in issuing a closure notice an officer of HMRC is performing an important public function in which fairness to the taxpayer must be matched by a proper regard for the public interest in the recovery of the full amount of tax payable. HMRC were therefore not limited to the grounds stated in the notice. On the substantive issue, the decision serves as a reminder that the implementation of transactions with a tax saving element is of the utmost importance. The Court essentially followed the general approach in previous case law and held that entitlement to capital allowances required there to have been real expenditure for the real purpose of acquiring plant or machinery for use in a trade.