CL-2018-000297, CL-2018-000404, CL-2018-000590, - [2025] EWHC 2979 (Comm)

I considered that, in substance, SKAT was seeking by Grounds 2 and 3 just to re-run on appeal factual cases that it did not prove at trial, and that there was not more than a fanciful prospect of a conclusion that it might meet the appellate test it acknowledged, as stated for example in Henderson v Foxworth Investments Ltd et al [2014] UKSC 41, [2014] 1 WLR 2600 at [67], per Lord Reed JSC.