Hundal v Revenue & Customs (INCOME TAX/CORPORATION TAX : Other) [2018] UKFTT 469 (TC) (20 July 2018)

Hundal v Revenue & Customs (INCOME TAX/CORPORATION TAX : Other) [2018] UKFTT 469 (TC) (20 July 2018)

The information and documents requested in the information notices were reasonably required for the purpose of checking the Appellant’s tax position. The notices were valid taxpayer notices, not disguised third party notices. The penalties for non-compliance were valid as there was no reasonable excuse. Applications...

Source-derived case information.

Citation
[2018] UKFTT 469
Parties
Appellant: Amarjit Singh Hundal; Respondents: The Commissioners for Her Majesty’s Revenue & Customs
Jurisdiction
United Kingdom
Judgment Date
20 July 2018
Procedural Posture
Tax Appeal / Final Judgment
Outcome
Appeal dismissed
Legal Topics
Information Notices, Penalties, Closure Notices, Statutory Records, Jurisdiction of Tribunal
Tax Law Information Notices Penalties Closure Notices Statutory Records Jurisdiction of Tribunal

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Parties

Amarjit Singh Hundal

Appellant

The Commissioners for Her Majesty’s Revenue & Customs

Respondents

Procedural Posture

Tax Appeal / Final Judgment

Legal Issues

  1. 1 Whether information and documents requested in information notices were reasonably required for checking the Appellant’s tax position
  2. 2 Whether the information notices were valid taxpayer notices or disguised third party notices
  3. 3 Whether penalties for non-compliance with information notices were valid

Ratio Decidendi

The information and documents requested in the information notices were reasonably required for the purpose of checking the Appellant’s tax position. The notices were valid taxpayer notices, not disguised third party notices. The penalties for non-compliance were valid as there was no reasonable excuse. Applications for closure notices were premature due to outstanding information required by HMRC.

Court Disposition

Appeal dismissed

Orders

  • Appeals against information notices dismissed
  • Appeals against penalty notices dismissed