Expenditure on constructing buildings on land already held did not qualify for rollover relief (following a compulsory purchase), but HMRC’s discovery assessment in respect of the relief claim was based on a discovery that was ‘stale’ and, therefore, invalid. 
 
The appellant company disposed of land under a compulsory purchase order on 27 November 2009, realising a capital gain. The appellant’s corporation tax self-assessment return for the accounting period ended 31 August 2010 contained a provisional rollover relief claim (under TCGA 1992, s 247A). 
 
On 16 April 2012, the appellant reinvested the entire disposal proceeds into the construction and erection of industrial workspace in two blocks on land that the appellant already owned. The appellant claimed relief under TCGA 1992, s 247 on the basis that it superseded the provisional claim. 
 
On 15 May,