THE COMMISSIONERS FOR HIS MAJESTY’S REVENUE and CUSTOMS v SHAUN HARTE [2026] UKUT 00112 (TCC)
Upper Tribunal Tax and Chancery decision of JUDGE SWAMI RAGHAVAN AND JUDGE KEVIN POOLE on 12 March 2026
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INCOME TAX – discovery assessments under s29 TMA 1970 containing multiple insufficiencies of tax– whether taxpayer can argue overcharged to the extent insufficiencies not brought about carelessly or deliberately and/or that extended time limits under s36 TMA not met – yes – FTT Decision upheld – appeal dismissed