The House of Lords has reversed the decision of the Court of Appeal and has held that section 27 of Capital Gains Tax Act 1979 (now section 28 of the Taxation of Chargeable Gains Act 1992) had a single limited aim, which was the timing of a disposal. It did not say that the contract was a disposal nor did it identify the parties to the disposal. Rather, it had the effect such that the disposal effected by the contract and later completion was to be treated for timing purposes as made at the date of the contract.