[2024] UKUT 00390 (TCC)

Mr Bedenham, on behalf of the Applicant also seeks permission to appeal on the following ground: The FTT held that the Appellant had deliberately understated its tax liabilities (see paragraphs 309-313 and 353 of the FTT decision). However, the FTT erred in making that finding in circumstances where (as the FTT acknowledged at paragraphs 238 and 241) HMRC had not alleged (and it was not open to the FTT to find) that the Appellant had behaved dishonestly.

He submits that whether the Appellant behaved deliberately was relevant to:

whether some of the corporation tax assessments were made in time (see paragraph