Final assessment rendered the challenge infructuous; interest and unjust enrichment remained subject to the Tribunal's result.

Challenge became infructuous after the final assessment, and the SC disposed of the appeal on that basis. The questions relating to interest and unjust enrichment were left to be dealt with in accordance with the Tribunal's result and any interim order in force. The operative effect is that no separate substantive determination was made on those issues in the appeal, and their treatment remains tied to the Tribunal's outcome and interim directions, if any.

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Outcome: The appeal was disposed of after the Court treated the challenge as infructuous in view of the final assessment and left the question of interest and unjust enrichment to be dealt with in accordance with the Tribunal's result and the interim order, if any.

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