References: [2015] UKUT 579 (TCC)
Links: Bailii
UTTC Ratio 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
Last Update: 06-May-16
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