(1)A company on which a counteraction notice has been served may appeal on the grounds that—
(a)section 733 (company liable to counteraction of corporation tax advantage) does not apply to the company in respect of the transaction or transactions in question, or
(b)the adjustments directed to be made are inappropriate.
(2)Such an appeal may be made only by giving notice to the Commissioners for Her Majesty's Revenue and Customs within 30 days of the service of the counteraction notice.
(3)On an appeal under this section the tribunal may—
(a)affirm, vary or cancel the counteraction notice, or
(b)affirm, vary or quash an assessment made in accordance with the notice.
(4)But the bringing of an appeal under this section does not affect—
(a)the validity of the counteraction notice, or
(b)the validity of any other thing done under or in accordance with section 746 (counteraction notices),
pending the determination of the proceedings.