No reasonable grounds exist for believing Newcastle United engaged in a suspected tax fraud, two High Court judges have been told.
Club officials are challenging the seizure of documents by tax officials investigating the financial affairs of several football clubs.
St James' Park and West Ham United's ground were raided in April by HM Revenue and Customs (HMRC) as part of a probe into suspected income tax and national insurance fraud.
Newcastle's managing director Lee Charnley was among a number of senior European football officials arrested and later released without charge.
The club is challenging the legality of the search-and-seize orders obtained by HMRC at Leeds Crown Court.