INCOME TAX – Penalty – Section 93A Taxes Management Act 1970 – late submission of partnership return – appeal submitted by a partner other than the ‘representative partner’ – whether Tribunal has jurisdiction to hear appeal – whether penalty invokes criminal head of Article 6.1 of European Convention on Human Rights – whether absence of direct right of appeal by the appellant denial of right to fair hearing – whether restrictions on right of appeal mean Tribunal is not a tribunal of ‘full jurisdiction’ for the purposes of the Convention – whether Section 93A can be construed to give effect to Convention rights
Citations:
[2012] UKFTT 483 (TC)
Links:
Jurisdiction:
England and Wales
Taxes Management, Human Rights
Updated: 10 November 2022; Ref: scu.466105