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HMRC’s check and the appeal
HMRC’s check and the appeal
On 10 July 2023 HMRC notified the Appellant that they would be checking the 09/22 Return. The details of the correspondence between the parties is not relevant save that we find as set out below.
The Appellant was asked by HMRC to complete a questionnaire about its business activities and to provide information. including bank statements, purchase/sale ledgers and copies of invoices. HMRC considered the information provided and made a number of further requests.
On 22 September 2023 Mr Naveed, in a covering e mail enclosing some information, stated that all stock had been used to build the two houses at Cromley Road (as to which see below).
On 6 October 2023 HMRC issued a notice of assessment to the Appellant which:
increased the output tax due from £21,693.03 originally declared in the 09/22 Return to £123,077.50; and
denied the Appellant the recovery of the £68,556.28 input tax claimed.
On 7 December 2023, following a request for an internal review, HMRC issued the outcome of the internal review which:
reduced the output tax assessment from £123,077.50 to £16,553.37; and
upheld the denial of input tax.
On 4 January 2024, the Appellant appealed to this Tribunal.