VAT – PLNs – deliberate inaccuracy penalties after denial of zero rating by trader applying Mecsek-Gabona; whether underlying assessments should be considered – yes – had HMRC sufficiently identified link to fraudulent tax loss – no – appeals allowed
Procedural – whether an issue should be dealt with as a preliminary issue – Wrottesley applied – no; submission of no case to answer – decision that the application would not be entertained.
Source: bailii.org
