The appellant appealed to the First-tier Tribunal (FTT) following a repayment claim to HMRC that it found related to exempt supplies and that the appellant was not entitled to a VAT repayment relating to those supplies. That being the case, HMRC then sought to recover the VAT repayments for the earlier periods, deregistered the appellant for VAT and issued penalty assessments. 

HMRC conceded that the assessments and penalties for periods 05/17 to 02/18 inclusive had not been issued timeously and therefore both they and the related penalties were not valid. The assessment for 05/18 had never been issued, so it, too, was not valid and nor was the associated penalty. 

Accordingly, the VAT returns and penalties for periods 08/18 to 02/21 inclusive, together with the decision relating to period 02/21 and the decision to deregister, were now the only subject matter of the appeal. 

The appellant had originally registered for VAT in