UT/2019/000009 - [2024] UKUT 00176 (TCC)

In this section we briefly summarise those case-law propositions relevant to putting Mr Ali’s grounds into context. We did not understand there to be any real dispute over the legal principles relevant to whether an assessment ought to have been made on an earlier supplier, and as to what constitutes “holding” (although as will be seen the principles have been progressively clarified over the period from when the FTT heard the case, issued its decision, the Upper Tribunal gave permission and when the appeal was heard before us). Rather the grounds concern whether the FTT Decision misinterpreted and/or misapplied those principles.