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Grounds 3-5
Grounds 3-5
In brief, Grounds 3 and 5 challenge the rationality of HMRC’s conclusion that the claimant’s circumstances did not fall within the SP. Ground 4 alleges various errors of law in HMRC’s analysis that the claim should have been made earlier. It also alleges that HMRC failed to take account of various considerations. I will address the further relevant detail of these grounds, and HMRC ‘s response to them, in the discussion section below.
- 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