Dr Vasiliki Raftopoulou v The Commissioners for HM Revenue and Customs: [2015] UKUT 0579 (TCC)
Upper Tribunal Tax and Chancery decision of Judge Berner and Judge Raghavan on 16 October 2015.
Read the full decision in .
INCOME TAX – whether deeming provision in s 118(2) TMA could apply to deem out of time claim for repayment of income tax under Schedule 1AB TMA to have been in time where taxpayer had reasonable excuse – yes – whether tribunal had jurisdiction to hear the issue of whether claim out of time – yes – whether provisions on notices of enquiry and closure notices in Schedule 1A TMA enabled notice of enquiry and closure to be issued in immediate succession and in one document- yes - UT’s decision in Portland Gas Storage Limited considered - appeal allowed.
Published 1 December 2016