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The PTA Application also includes a further ground which was cross-referenced to internal paragraph 8, but that cross-reference was erroneous. I thought the ground might instead reference to 4site,and to applications made under CPR 18, but if so, for the reasons given earlier, neither assists HMRC.
Overall conclusion on PTA of the Second Decision
For the reasons set out above, I refuse permission to appeal against the Second Decision.
- Heading
- Introduction
- Publication of this decision
- The Salaried Member Rules
- The Compliance Check
- The Determinations
- The Appeal
- The F&B Application
- The First Decision
- The case law
- Schedule 36
- Duty to give reasons and Reg 80
- The Tribunal Rules
- Overall conclusion
- The PTA application in relation to the First Decision
- The case law
- The Grounds of the PTA Application
- Ground 1: Rule 20
- Ground 2: duty to give reasons
- Ground 3: burden of proof
- Ground 4: positive case
- Ground 5: case management of the appeal
- Ground 6: 4Site
- Ground 7
- Overall conclusion on the PTA Application relating to the First Decision
- The Statement of case
- The SoC Application
- The law
- Failure to provide full information?
- Failure to provide “any evidence of what the SMR position is”
- Acceptance in correspondence that the SMR had been incorrectly applied?
- Reliance on the fraud?
- Out of time Determinations
- Overall conclusion
- Directions
- PTA Application in relation to the Second Decision
- A bare assertion?
- The TMA
- The case law
- Duty to give reasons
- Discerning the Appellant’s case?
- The Directions
- Barring Order
- Other submissions
- Other
- Next steps