Part of the ground floor of a property was used for commercial purposes at the relevant date, but the property as a whole was either used as a dwelling or suitable for use as a dwelling and therefore comprised residential property in its entirety.  

The appellant purchased a building known as the Bacon Factory (BF) in June 2021 for £5.75m. BF comprised three floors. It was originally used for smoking bacon. By 1985, permission had been given to convert the upper two floors to residential accommodation. The ground floor remained designated for planning purposes as light industrial. The ground floor had been subject to non-domestic (business) rates from at least 1990.  

The ground floor was split into two parts. The front area consisted of a garage space with storage including an area which was walled off with fireproof glass which had been intended to house a gin still. The garage area had two sunken car spaces which allowed