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.
Citations:
[2022] UKUT 116 (TCC)
Links:
Jurisdiction:
England and Wales
Taxes Management
Updated: 31 May 2022; Ref: scu.677625