[2025] EWHC 2336 (Ch)

The suggestion is that the delay in service of the demand notices was extravagant and unexplained, and that the defendant has a legitimate expectation, and arranges its affairs on the basis, that billing authorities will act in accordance with their statutory obligations so as not to surprise taxpayers with a substantial tax liability years after the event.

However, I have already found that there was no such delay. Had there been any, I should have found that it was nothing of which the defendant could complain, since it would have arisen from its own lack of candour. I would not accept that the defendant had been surprised in any event.