TC09596 - [2025] UKFTT 00895 (TC)

Having considered all of the evidence, cumulatively, we are satisfied that the appeal succeeds on the Supply Issue but fails on the Legitimate Expectation Issue. Accordingly, therefore, we allow the appeal on the Supply Issue and set aside the Assessments.

This document contains full findings of fact and reasons for the decision. Any party dissatisfied with this decision has a right to apply for permission to appeal against it pursuant to Rule 39 of the Tribunal Procedure (First-tier Tribunal) (Tax Chamber) Rules 2009. The application must be received by this Tribunal not later than 56 days after this decision is sent to that party. The parties are referred to “Guidance to accompany a Decision from the First-tier Tribunal (Tax Chamber)” which accompanies and forms part of this decision notice.