This appeal was against a decision by HMRC to issue the appellant with a penalty under s. 62(1) and (2) of the Value Added Tax Act 1994 in the sum of £20, 937. 

The penalty arose from the decision by the appellant to issue a zero-rating certificate to Atkinson Builders Ltd on 9 March 2013 in relation to supplies to it during the course of the construction of a new pavilion. 

Background 

The only issue before the Tribunal was whether or not the appellant could prove to the requisite standard that it had a reasonable excuse for issuing the zero-rating certificate, it having been conceded that the appellant ought not to have issued the zero-rating certificate. 

The appellant was a cricket club run by unpaid volunteers with a love for village cricket. Mr. Kellock has