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Conclusions
Conclusion
The appeal is dismissed.
JUDGE SWAMI RAGHAVAN
JUDGE MARK BALDWIN
Release date: 30 June 2025
- Heading
- Introduction
- law
- Background and FTT Decision
- Grounds of appeal
- Ground 2 – failure to draw the only reasonable conclusion from the evidence
- Appellant’s Ground of Appeal
- Discussion
- Ground 3 – erroneous evidential standard – reliance on Griffiths v TUI in Court of Appeal – which was overturned in Supreme Court
- Ground 4 – FTT wrongly relied on terms of VAT Notice 725 to exclude P&O boarding cards and other supplementary evidence
- Discussion on Ground 4
- Ground 5 - failure to apply EU law
- Ground 6 – Failure to find evidence of commercial system
- Ground 1 – unacceptable delay
- Conclusions