Summary
In 2011 the Appellant accepted that it had made an error by not recharging certain costs to an associated company, Temple Finance Limited (“TFL”). Correspondence ensued between the Appellant and HMRC as to the amount of VAT underpaid.
HMRC raised an assessment on 31 January 2013 for £79,235.
The issue before the Tribunal was whether that assessment was made more than one year after “evidence of facts, sufficient in the opinion of the Commissioners to justify the making of the assessment, came to their knowledge” and thus whether it was out of time by virtue of section 73(6)(b) of the Value Added Tax Act 1994 (“VATA”).
Background
This appeal concerns the recharging of costs on a number of vehicles which were originally used only for its own business. As the business grew, some of the vehicles began to be
