Decision Number: |
TC 01322 |
Appellant:
|
HMD Response International |
Respondent:
|
The Commissioners for Her Majesty's Revenue & Customs |
Chairmen / Special
Commissioners: |
Geraint JONES QC
|
Date Of Decision:
|
15/07/2011 |
Main Category:
|
INCOME TAX/CORPORATION TAX |
Main Subcategory:
|
Penalty |
Notes:
|
Penalty; late filing; fairness; s98A(2)(a) TMA 1970. Common law fairness. Conscionable conduct. Jusilla v Finland. “Reasonable excuse” does not necessarily involve any exceptional circumstance. Honest and genuine belief amounts to “reasonable excuse”. Burden of proof. |
Decision(s) to Download:
|
TC01322.pdf
|