HMRC Application For Permission To Appeal To The Upper Tribunal

This case was an HMRC application for permission to appeal to the Upper Tribunal in a case where they had initially lost in the First-tier Tribunal on the matter of whether Discovery Assessments issued under TMA 1970 S.29 when they had argued that the concept of “staleness” could not render an assessment invalid. Having lost in the initial hearing HMRC were refused permission to appeal.

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