In Golamreza Qolaminejite (aka Anthony Cooper) v HMRC [2021] UKUT 0118, the Upper Tribunal (UT) found the FTT had not considered all the relevant evidence in determining that unexplained receipts were subject to tax as business income. It also concluded that the FTT had considered a contract appropriately and that an input VAT claim was blocked as there was no evidence of a supply being made.

UT found:


Overall, one heck of a mess. This is one of those cases where, with the benefit of hindsight, the taxpayer should have put a lot more into the initial appeal to the FTT. In the first appeal the taxpayer provided additional evidence a week before and further late evidence was not admitted as it was only provided on the day.

Useful guides on this topic

Discovery Assessments 
When can HMRC issue an assessment outside of the normal statutory time limits? What conditions must be met? What are your rights of appeal and defences?

How to appeal an HMRC decision 
Disagree with a HMRC decision? How to appeal, what type of decision can you appeal, what are your different options when you disagree with HMRC? What are the key steps in making an appeal?

Time limits  for tax assessments, claims and refunds
What are the time limits for claiming a tax refund? How far can HMRC go back and raise an assessment? How many years back can a taxpayer appeal? What are the time limits for correcting a tax return?

External links

Golamreza Qolaminejite (aka Anthony Cooper) v HMRC [2021] UKUT 0118


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