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UPPER TRIBUNAL Neutral Citation No. [2025] UKUT 00377 (TCC)
TAX AND CHANCERY CHAMBER
Applicant: Haron Mayet | Tribunal Ref: UT-2025-000040 |
Respondents: The Commissioners for His Majesty’s Revenue and Customs | |
RECONSIDERATION OF APPLICATION FOR PERMISSION TO APPEAL FOLLOWING ORAL HEARING
DECISION NOTICE
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- 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