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Claimant’s Grounds of judicial review and HMRC’s defence
Claimant’s Grounds of judicial review and HMRC’s defence
For present purposes it is relevant to note the following issues raised by the claimant’s detailed statement of grounds of 9 April 2024 and HMRC’s response to those in their grounds of resistance of 30 April 2024. HMRC’s response identifies, at the outset, that the reasons for its decision not to extend time are set out in its decision letter of 5 January 2024.
- Heading
- Introduction
- Background
- Claimant’s Grounds of judicial review and HMRC’s defence
- Ground 1
- Ground 2
- Grounds 3-5
- HMRC Officer Ms Murphy’s 23 August 2024 Witness Statement
- Legal principles
- The disclosure sought and outline of parties’ submissions
- Discussion
- Inconsistencies mean disclosure appropriate?
- Whether disclosure necessary to resolve issues fair and justly in relation to issues raised
- Conclusions