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Deliberate issue
Deliberate issue
Legal test
The legal test on what constitutes deliberate conduct (both for the purposes of the gateway to the issue of a discovery assessment in accordance with paragraph 43 Sch 18 FA98 (Footnote: 8) and Sch 24 FA 2007) has been confirmed in the Tooth Supreme Court judgment at paragraphs 42, 43 and 47 which provide that deliberate conduct requires that a statement is made which, when made, was intentionally misleading.
- Heading
- Introduction
- Brief factual and procedural background
- Burden of Proof
- Evidence
- Parties submission
- Findings of fact
- Evidence
- Parties submissions
- Findings of fact
- Best Judgement Issue
- Evidence
- Parties submissions
- Findings of fact
- VAT Quantum Issue
- Parties submissions
- Evidence
- Input Tax Issue
- Discussion
- Works on premises in Leicester
- 7 Wilmslow Road
- Vehicle hire invoices
- Birmingham Hotels invoices
- Discovery Issue
- Findings of fact
- Deliberate issue
- Parties submissions
- Findings of fact
- Participation Issue
- PLN Issue
- Findings of Fact
- Mitigation Issue
- Parties submissions
- Findings of fact
- Conclusions