CF Booth Limited v Revenue and Customs [2022] UKUT 217 (TCC) (9 August 2022)
Procedure - Value Added Tax - appeal against penalties under Schedule 24 FA 2007 for deliberate inaccuracy in returns - application by HMRC to strike out parts of appeal for abuse of process - 2017 FTT decision that Appellant knew that its transactions connected to fraudulent evasion - 2020 FTT decision striking-out parts of the penalty appeal - whether appeal an abuse of process - application of Art 6 European Convention on Human Rights - whether issue not raised before FTT suitable for determination even though permission to appeal granted - Mullarkey v Broad applied
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