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Particular supplies?
Particular supplies?
As noted at §45, the Application was not limited to documents and information about the particular supplies in question. Mr Mciver said that restricting the Application so that it related only to the particular supplies for which duty had been charged would make it more proportionate. However, Mr Thornton’s position, with which I again agree, was that this would unduly narrow the scope – there could, for example, be uncertainties as to exactly which goods in the supply chains ended up at UWG.
- Heading
- Introduction
- The law
- Liability to excise duty
- The burden of proof
- Judicial review
- Disclosure
- The Application
- Mr Thornton’s submissions on behalf of UWG
- Mr Mciver’s submissions on behalf of HMRC
- Disclosure was inappropriate in principle?
- UWG failed to carry out appropriate checks?
- Judicial review
- Scope too wide/fishing expedition?
- Disproportionate?
- Particular supplies?
- Not fair and just?
- Flaws in the Application?
- Conclusions