This was an appeal to the Upper Tribunal (UT) from the First-tier Tribunal (FTT) against its decision that the hair replacement system which the appellant offered to women suffering from baldness qualified for zero-rating under VATA 1994, Sch 8, Gp 12 or whether the supply should be standard-rated. The amount of VAT at issue in the periods, including those from 01/18 to 01/24, comes to £277,083. The FTT concluded the hair replacement system did not qualify for zero-rating and dismissed the appellant's appeal.  

The appellant appealed on the grounds that the FTT erred in law in that its reasoning was inadequate or otherwise flawed in various respects. The FTT did not explain why baldness in women was not a physical or mental impairment which had a long-term and substantial adverse effect on their ability to carry out everyday activities. 

The UT considered the