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Introduction
Introduction
The form of the hearing was V (video).
The documents to which we were referred are:
a 174-page authorities bundle of legislation and case law;
a 62-page documents bundle (of which the last 27 pages consisted of two further case reports); and
a 15-page submission (statement of reasons) prepared on behalf of HMRC.
Prior notice of the hearing had been published on the gov.uk website, with information about how representatives of the media or members of the public could apply to join the hearing remotely in order to observe the proceedings. As such, the hearing was held in public.
At the end of the hearing, when we had announced our decision, Mr Chaudhary requested this full decision notice in accordance with rule 35(3)(b).
- Heading
- Introduction
- Overview of the case
- The legislative scheme
- The case law on reasonable excuse
- The case law on special reduction
- Findings of fact
- The Appellant’s complaint to HMRC
- Penalty for late payment
- Reasonable excuse
- Discussion
- Special reduction
- HMRC’s arguments
- The Appellant’s arguments
- Discussion
- Conclusions