Value added tax – Input tax. The Upper Tribunal (Tax and Chancery Chamber) had been wrong to have concluded that an allegation that a taxpayer knew that its transactions were part of an orchestrated scheme to defraud the Revenue and Customs Commissioners (the Revenue) required the Revenue to plead and particularise, and therefore prove, an allegation of dishonesty. The Court of Appeal Civil Division so held in hearing an appeal in relation to refusals to deduct input tax by the Revenue in respect of two separate taxpayers.