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Grounds of Appeal
Grounds of Appeal
The Applicant originally submitted grounds of appeal to the UT in an application for permission to appeal and a notice of appeal dated 22 April 2025. There were three revised grounds of appeal dated 24 October 2025 which I address below:
- 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