This is an appeal against HMRC's decision to reduce the appellant's VAT repayment claim for the 12/23 period from £29,394.80 to £76.00. The reduction was based on two sets of purchases: 77 transactions for which tax invoices that were provided to HMRC were shown to have been dated many months after the repayment claim was made, and 24 transactions for which no tax invoices or any other supporting evidence had been provided to HMRC.

The investigation formally commenced with a written request for the sight of the six invoices representing the highest amount of VAT, the VAT audit trail and the appellant's bank statements for the periods under review. Over the next six months, despite a number of repeated requests, this information was not sent. However, a list of 101 purchase invoices comprising the £29,394.80 input tax claim for the 12/23 period was provided.

HMRC requested copies of the invoices in August 2024 but only 77