Golamreza Qolaminejite (aka Anthony Cooper) v The Commissioners for HM Revenue and Customs [2021] UKUT 0118 (TCC)
Jurisdiction | UK Non-devolved |
Judge | Judge Swami Raghavan,Judge Andrew Scott |
Neutral Citation | [2021] UKUT 0118 (TCC) |
Subject Matter | 21 May 2021 |
Court | Upper Tribunal (Tax and Chancery Chamber) |
Published date | 24 May 2021 |
[2021] UKUT 0118 (TCC)
Appeal number:
UT/2020/0004
INCOME TAX / VALUE ADDED TAX–– whether FTT erred in not weighing
probability of HMRC’s assessment based on unidentified deposits
representing appellant’s trading income against appellant’s case – whether
FTT erred in contractual interpretation – whether FTT erred in impermissibly
reaching own view on original document that had been translated – whether
FTT erred in concluding no transaction had taken place and refusing
appellant input VAT in circumstances where supplier had been wound up for
non-payment of output VAT – appeal allowed in part – case remitted to FTT
to address appellant’s argument that deposits could not have been trading
income due to lack of trading activity
UPPER TRIBUNAL
(TAX AND CHANCERY CHAMBER)
GOLAMREZA QOLAMINEJITE
(aka ANTHONY COOPER)
Appellant
-and-
THE COMMISSIONERS FOR HER MAJESTY’S
REVENUE AND CUSTOMS
Respondents
Sitting in public by way of remote video Microsoft Teams hearing, treated as taking place
in London, on 15 February 2020
Ross Birkbeck, counsel, for the Appellant
Marianne Tutin, counsel, instructed by the General Counsel and Solicitor to HM Revenue
& Customs, for the Respondents
TRIBUNAL:
JUDGE SWAMI RAGHAVAN
JUDGE ANDREW SCOTT
2
© CROWN COPYRIGHT 2021
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