Wyatt Paul v The Commissioners for HM Revenue and Customs [2022] UKUT 00116 (TCC)
Upper Tribunal Tax and Chancery decision of Upper Tribunal Judge Swami Raghavan on 25 April 2022
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Procedure–– whether Respondent in UT appeal needs UT’s permission to argue new point that was not argued before the FTT – yes – permission to raise new point (on estoppel by convention) Refused.
Published 28 April 2022