It was held that in following the procedure laid down by the Act and not extending it to give the taxpayers the right to see the counterstatement, the tribunal was not acting unfairly or contrary to the rules of natural justice.

• 判决认为，法庭已遵从了该财政法规定的程序，没有给予纳税人查阅答辩材料权利的做法并未有失公允或违反自然公正原则。