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52(1)On the determination of an appeal under paragraph 35 any tax overpaid must be repaid.
(2)On the determination of an appeal under paragraph 35, section 163(payment of tax) has effect in relation to any relevant tax as if—
(a)the tax were payable in accordance with an assessment under paragraph 22 issued on the date on which HMRC issues to the appellant a notice of the total amount payable in accordance with the determination, and
(b)there had been no appeal against that assessment.
(3)The reference in sub-paragraph (2) to “relevant tax” is to any tax payable in accordance with the determination, so far as it is tax—
(a)the payment of which had been postponed, or
(b)which would not have been charged by the amendment or assessment if there had been no appeal.
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