Paul Harrison v The Commissioners for HM Revenue and Customs [2023] UKUT 00038 (TCC)

Upper Tribunal Tax and Chancery decision of Judge Thomas Scott and Judge Ashley Greenbank on 03 February 2023

• From: HM Courts & Tribunals Service and Upper Tribunal (Tax and Chancery Chamber)
• Published: 6 February 2023

• Category: Tax
• Release date: 3 February 2023

Read Full Decision PAUL HARRISON v HMRC Final Decision issue to Parties

INCOME TAX - discovery assessment - whether HMRC had discharged burden of establishing discovery - whether the Upper Tribunal is bound to follow the decision of the Court of Appeal in Tooth that a discovery assessment may become “stale” because the contrary decision of the Supreme Court in that case was obiter - quantum of assessment - appeal dismissed

Published 6 February 2023