UT (Tax & Chancery) UT/2023/00099 - [2025] UKUT 00013 (TCC)

All relevant invoices had first been requested by HMRC in the email from Officer Mills dated 18 October 2018; he repeated that request in formal letters dated 7 and 25 January 2019.

In its correspondence with HMRC between October 2018 and 4 March 2019, the Appellant did not provide HMRC with the Verity invoices, although it had asserted that it held “between 800 and 1000 invoices from different suppliers” in relation to each of the Verity amounts, and it had offered to make its business records available to HMRC to inspect.

Thus, at the time Officer Mills issued the assessments, the Appellant had not provided the Verity invoices, and he made his decision on the basis that the Appellant had provided “insufficient information to evidence the input tax deducted”.