Customs and excise – Duties. The respondent Revenue and Customs Commissioners had not had knowledge of the evidence of facts contained in certificates of conformity until it had read and digested their contents, which had not happened before the critical cut-off date for limitation purposes. Accordingly, the Court of Appeal, Civil Division, in dismissing the taxpayer's appeal, held that the First-tier Tribunal (Tax Chamber) and the Upper Tribunal (Tax and Chancery Chamber) had correctly applied s 12(1) of the Finance Act 1994.