Customs and excise – Duties. The exception from liability for payment of excise duty, established by caselaw for those who were 'innocent agents', extended to those who lacked any knowledge (actual or constructive) of the fact that the goods found in their possession were or would be duty unpaid. Such persons were not 'making the delivery' or 'holding' the goods for the purposes of the Excise Goods (Holding, Movement and Duty Point) Regulations 2010, SI 593/2010. The Upper Tribunal (Tax and Chancery Chamber) so held in proceedings against the taxpayer who had been stopped while driving a heavy goods vehicle into the UK with pallets of beer on which excise duty was due but had not been paid.