Decision Summary Information |
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Decision Number: | V/18359 |
Appellant: | Hospitality Training Foundation |
Respondent: | The Commissioners of Customs & Excise |
Chairmen / Special Commissioners: |
His Honour Stephen
OLIVER
QC
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Date of Decision: | 31.10.2003 |
Main Category: | VAT - INPUT TAX |
Main Subcategory: | Apportionment |
Secondary Category: | VAT - ASSESSMENTS |
Secondary Subcategory: | Time limits |
Notes: | |
INPUT TAX - partial exemption - special method - trader makes taxable and exempt supplies and has "outside-the-scope" activities - construction of original special method - whether it permitted apportionment of all overheads to taxable and exempt supplies to exclusion of any outside-the- scope activities - no - whether it permitted relief for input tax on inputs directly attributed to outside-the-scope activities - no - whether method changed following visit of assurance officers such that both reliefs could be claimed - no ASSESSMENT - time limits - whether Commissioners had knowledge of sufficient facts to enable assessments to be made - yes - VAT Act S73(6)(b) ASSESSMENT - best judgment - whether misunderstanding of partial exemption method violated best judgment character of assessment - no - VAT Act S73(1) |
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Decision to Download: | No copy available |