Patel v Revenue & Customs [2011] UKFTT 104 (TC) (03 February 2011)

There are reasonable grounds for believing the appellant was overcharged to tax for the years 1989-90 to 1995-96, but not for the years 1996-97 to 2007-08.

Citation: [2011] UKFTT 104
Parties: Appellant: Harish Patel; Respondents: The Commissioners for Her Majesty’s Revenue and Customs
Jurisdiction: United Kingdom
Judgment Date: 03 February 2011
Procedural Posture: Income Tax/corporation Tax Appeal / Application for Postponement of Tax Assessment
Outcome: Application allowed in part
Legal Topics: Postponement of Tax, Protective Assessments, Interest Income, Section 55 Taxes Management Act 1970

Tax Law Postponement of Tax Protective Assessments Interest Income Section 55 Taxes Management Act 1970

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Parties

Harish Patel

Appellant

The Commissioners for Her Majesty’s Revenue and Customs

Respondents

Procedural Posture

Income Tax/corporation Tax Appeal / Application for Postponement of Tax Assessment

Legal Issues

1 Whether there are reasonable grounds for believing the appellant is overcharged to tax under the assessments for the years 1989-90 to 2007-08

Ratio Decidendi

There are reasonable grounds for believing the appellant was overcharged to tax for the years 1989-90 to 1995-96, but not for the years 1996-97 to 2007-08.

Court Disposition

Application allowed in part

Orders

Tax due between 1989-90 to 1995-96 is postponed.
Application for postponement for tax due between 1996-97 to 2007-08 is dismissed.