Newcastle's managing director, Lee Charnley, whose home was also searched, was among a number of senior European football officials arrested and later released without charge.

Business and financial records were seized, as well as computers and mobile phones belonging to the club, which recently secured promotion to the Premier League.

The HMRC investigation centres on football agents and payments made in transfer dealings between English and French clubs.

Two judges, sitting in London today, rejected a challenge by Newcastle over the legality of search-and-seize orders obtained by HMRC from a judge at Leeds Crown Court.

Announcing the decision to dismiss the club's application for judicial review, Lord Justice Beatson and Mrs Justice Whipple ruled: "The warrants were lawfully issued."

At a hearing in July, the judges heard argument on behalf of the club that no reasonable grounds existed for believing it had engaged in suspected tax fraud.

But HMRC argued in court that reasonable grounds existed for believing Newcastle United FC was ''knowingly involved'' in a multimillion-pound tax fraud when club offices were raided.

Court orders have so far prevented HMRC officers from examining the seized material pending the outcome of the legal action.