This appeal was against a decision by HMRC to issue the appellant with a penalty under VATA 1994, s 62(1) and (2) in the sum of £20, 937.

The penalty arose from the decision by the appellant to issue a zero-rating certificate to Atkinson Builders Ltd on 9 March 2013, in relation to supplies to it during the course of the construction of a new pavilion.

Background

The only issue before the First-Tier Tribunal (FTT)was whether or not the appellant could prove to the requisite standard that it had a reasonable excuse for issuing the zero-rating certificate, it having been conceded that the appellant ought not to have issued the zero-rating certificate.

The appellant was a cricket club run by unpaid volunteers with a love for village cricket. Mr Kellock had been its treasurer since around