In HMRC v Ingenious Games (FTC/004/2014 – 7 February 2014) HMRC appealed against the decision of the FTT to dismiss its application for the disclosure of documents.
HMRC’s inquiry had been extremely wide ranging and in the interest of saving time and cost HMRC and the taxpayers had agreed that the inquiry would focus on a sample of transactions. However HMRC’s disclosure application was not limited to the agreed sample of transactions.
The UT ruled that it would be unfair and unjust for the taxpayers to ‘be able to suppress or keep from view of HMRC and the FTT relevant documents which may be harmful to their case as a consequence of the limitation on the extent of HMRC’s inspection of the documents during the investigatory stage’.
The UT also held that the FTT had been wrong when stating that the procedure rules ‘are not...
