Hm Courts Tribunals Service
August 16
12:27
2022
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Procedure Value Added Tax appeal against penalties under Schedule 24 FA 2007 for deliberate inaccuracy in returns application by HMRC to strike out parts of appeal for abuse of process 2017 FTT decision that Appellant knew that its transactions connected to fraudulent evasion ? 2020 FTT decision striking-out parts of the penalty appeal ? whether appeal an abuse of process ? application of Art 6 European Convention on Human Rights whether issue not raised before FTT suitable for determination even though permission to appeal granted Mullarkey v Broad applied