![UT/2023/000063 - [2024] UKUT 00307 (TCC)](https://backend.juristeca.com/files/emisores/logo_ICfrj4g.png){kind=logo}
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Neutral Citation: [2024] UKUT 00307 (TCC)
Case Number: UT/2023/000063
UPPER TRIBUNAL
(Tax and Chancery Chamber)
The Royal Courts of Justice,
Rolls Building, London
STAMP DUTY LAND TAX – building previously used as dwelling in need of renovation and repair at time of completion of purchase – whether building “suitable for use as a single dwelling”
Heard on: 28 June 2024
Judgment date: 01 October 2024
Before
JUDGE THOMAS SCOTT
JUDGE ASHLEY GREENBANK
Between
AMARJEET MUDAN AND TAJINDER MUDAN
Appellants
and
THE COMMISSIONERS FOR HIS MAJESTY’S REVENUE AND CUSTOMS
Respondents
Representation:
For the Appellants: Michael Firth KC, instructed by Cornerstone Tax 2020 Limited
For the Respondents: Michael Ripley, instructed by the General Counsel and Solicitor to His Majesty’s Revenue and Customs
DECISION
- Heading
- Introduction
- relevant legislation
- the ftt’s decision
- grounds of appeal
- repair and renovation: ftt decisions to date
- the appellants’ submissions
- hmrc’s submissions
- discussion
- Purposive construction
- Fiander UT
- Context
- Assessing suitability for use as a dwelling when building requires repair or renovation
- the ftt’s approach
- Conclusions