Summary 

The appellant appealed against assessments totalling £80,096, which had been raised by HMRC to recover VAT which had been claimed as input tax by the appellant for the periods 5/15 to 5/17 and 11/17. The appellant had claimed the recovery of input tax incurred on the purchase of doors and advertising costs. HMRC concluded that these amounts were not recoverable as they were not used by the business in the making of onward taxable supplies. The appellant accepted the disallowance of the input tax on advertising but appealed the disallowance of input tax on the purchase of the doors. 

Background 

The appellant’s main activity was commercial letting; it owned commercial properties which are used for a mixture of supplies – two are rented which were opted to tax, some were rented which