UTTC INCOME TAX – whether deeming provision in s 118(2) TMA could apply to deem out of time claim for repayment of income tax under Schedule 1AB TMA to have been in time where taxpayer had reasonable excuse – yes – whether tribunal had jurisdiction to hear the issue of whether claim out of time – yes – whether provisions on notices of enquiry and closure notices in Schedule 1A TMA enabled notice of enquiry and closure to be issued in immediate succession and in one document- yes – UT’s decision in Portland Gas Storage Limited considered – appeal allowed
Citations:
[2015] UKUT 579 (TCC), [2016] STC 656, [2015] STI 3364, [2015] BTC 532
Links:
Jurisdiction:
England and Wales
Income Tax
Updated: 03 June 2022; Ref: scu.558944