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Conclusions
Conclusion
Permission to appeal to the Upper Tribunal is refused.
Signed: Date: 4 November 2025 JUDGE RUPERT JONES JUDGE OF THE UPPER TRIBUNAL |
- Heading
- JUDGE RUPERT JONES Introduction
- UT’s jurisdiction in relation to appeals from the FTT
- Grounds of Appeal
- GROUND 1 – procedural unfairness (Rules 2, 29 and 30 of the Tribunal Procedure (First-tier Tribunal) (Tax Chamber) Rules 2009 (“FTT Rules 2009”))
- GROUND 2 – the FTT misdirected itself when applying the test for ‘deliberate accuracy’
- Ground 1b) – failure to adopt an inquisitorial approach
- Ground 2 –the FTT misdirected itself when applying the test for ‘deliberate accuracy’
- Ground 3 - the FTT failed to give adequate reasons for penalty findings
- Conclusion on grounds
- Conclusions