Tuesday 4 April 2023
By Appellant’s Notice filed on 26 September 2022, HMRC seeks permission to appeal the decision of the Upper Tribunal dated 12 July 2022 on the grounds for which permission has not already been granted.
Facts: the PTA arises out of an appeal against an FTT decision released on 23 March 2020. The FTT dismissed the appellants’ appeals against closure notices that HMRC had issued reducing their entitlement to capital allowances. The UT overturned the FTT decision.