Decision Number: | TC 08917 |
Appellant: | PRUTISH GOPAUL |
Respondent: | Her Majesty's Revenue & Customs |
Chairmen / Special Commissioners: |
ANNE REDSTON |
Date Of Decision: | 23/08/2023 |
Main Category: | PROCEDURE |
Main Subcategory: | Other |
Notes: | Corporation tax and VAT - corporation tax liability included a charge under CTA s 455 - penalties for deliberate behaviour - Personal Liability Notices - HMRC failed to meet burden of proving deliberate behaviour in relation to the s 455 part of the liability - appeal allowed in part |