UT/2024/000060 - [2024] UKUT 00315 (TCC)

Case Number: UT/2024/000060

Remote video hearing

JUDICIAL REVIEW – DISCLOSURE – Claimant’s interlocutory application for disclosure of documents (internal discussions and communication in run- up to issue of HMRC decision letter to refuse out of time claim) - documents not necessary for fair and just resolution of issues in case – application dismissed

Judgment date: 7 October 2024

Before

UPPER TRIBUNAL JUDGE SWAMI RAGHAVAN

Between

THE KING (on the application of)

RETTIG HEATING GROUP UK LIMITED

(IN LIQUIDATION)

Claimant

and

THE COMMISSIONERS FOR HIS MAJESTY’S REVENUE AND CUSTOMS

Defendants

Representation:

For the Claimant: Michael Firth KC, counsel, instructed by Joseph Hage Aaronson LLP

For the Defendants: Malcolm Birdling and Laura Ruxandu, counsel, instructed by the General Counsel and Solicitor to His Majesty’s Revenue and Customs

DECISION