Singh v Revenue & Customs [2013] UKFTT 171 (TC) (07 March 2013)

Singh v Revenue & Customs [2013] UKFTT 171 (TC) (07 March 2013)

It was reasonable for HMRC to require the full postal addresses of the individuals who allegedly provided loans or gifts to Mr Singh, as further evidence was needed to verify the taxpayer’s explanation for the deposits. However, requiring details of the relationship between Mr Singh and each payee was not reasonably required to check his tax position and was therefore struck out.

Citation
[2013] UKFTT 171 (TC)
Parties
Appellant: Steven Singh; Respondents: The Commissioners for Her Majesty’s Revenue & Customs
Jurisdiction
United Kingdom
Judgment Date
07 March 2013
Procedural Posture
Income Tax Appeal / First Tier Tribunal (tax Chamber) Decision on Appeal Against Information Notice Under FA 2008 Sch 36
Outcome
Appeal allowed in part
Legal Topics
Information Notice, Reasonably Required Information, Finance Act 2008 Schedule 36, Appeal Procedure
Tax Law Information Notice Reasonably Required Information Finance Act 2008 Schedule 36 Appeal Procedure

Case Brief

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Parties

Steven Singh

Appellant

The Commissioners for Her Majesty’s Revenue & Customs

Respondents

Procedural Posture

Income Tax Appeal / First Tier Tribunal (tax Chamber) Decision on Appeal Against Information Notice Under FA 2008 Sch 36

Legal Issues

  1. 1 Whether the information required by HMRC's Notice was reasonably required for the purpose of checking the taxpayer’s position under FA 2008 Sch 36 para 1(1)
  2. 2 Whether the requirement to provide payees' addresses and relationship details was justified

Ratio Decidendi

It was reasonable for HMRC to require the full postal addresses of the individuals who allegedly provided loans or gifts to Mr Singh, as further evidence was needed to verify the taxpayer’s explanation for the deposits. However, requiring details of the relationship between Mr Singh and each payee was not reasonably required to check his tax position and was therefore struck out.

Court Disposition

Appeal allowed in part

Orders

  • Mr Singh must provide a schedule showing the full current postal addresses of all individuals who provided loans and/or gifts in the relevant period, and unredacted bank statements showing these addresses, within one calendar month from the date of the decision.
  • The requirement to provide information about the relationship between Mr Singh and each payee is deleted from the Notice.