Paul Harrison v The Commissioners for HM Revenue and Customs [2023] UKUT 00038 (TCC)
Upper Tribunal Tax and Chancery decision of Judge Thomas Scott and Judge Ashley Greenbank on 03 February 2023
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INCOME TAX - discovery assessment - whether HMRC had discharged burden of establishing discovery - whether the Upper Tribunal is bound to follow the decision of the Court of Appeal in Tooth that a discovery assessment may become “stale” because the contrary decision of the Supreme Court in that case was obiter - quantum of assessment - appeal dismissed
Published 6 February 2023