I have a feeling that there is a done deal here in what is known as `At the door of the court`. I am still ploughing through the reasons, for what is a very odd decision handed down almost immediately after submissions. The CoA normally reserves judgement and goes away to consider the result.Courts are notorious for handing down perverse and inconclusive decisions, yet ACL are not appealing. Seems leading Counsel were changed for this hearing as well.Hmm time will tell and as you say Pabely maybe HMRC have had a say in this..Somebody certainly has.