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Parties submissions
Parties submissions
The Appellant does not challenge the reduction given in respect of the penalty associated with the sales from TSL, or the over claim to input tax. Neither do they challenge the reduction permitted for Telling or Giving in relation to the penalties issued in respect of the VAT errors associated with suppression at TSM or the corporation tax inaccuracies. However, they challenge the reduction for Helping contending that it is too low and that the justification for the level of mitigation is factually incorrect.
- 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