Golamreza Qolaminejite (aka Anthony Cooper) v The Commissioners for HM Revenue and Customs [2021] UKUT 0118 (TCC)
Upper Tribunal Tax and Chancery decision of Judge Swami Raghavan and Judge Andrew Scott on 21 May 2021
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INCOME TAX / VALUE ADDED TAX鈥撯�� whether FTT erred in not weighing probability of HMRC鈥檚 assessment based on unidentified deposits representing appellant鈥檚 trading income against appellant鈥檚 case 鈥� whether FTT erred in contractual interpretation 鈥� whether FTT erred in impermissibly reaching own view on original document that had been translated 鈥� 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 鈥� appeal allowed in part 鈥� case remitted to FTT to address appellant鈥檚 argument that deposits could not have been trading income due to lack of trading activity