Value Added Tax – Exemptions. The Upper Tribunal (Tax and Chancery Chamber) allowed the Revenue and Customs Commissioners' appeal against the decision of the First-tier Tribunal (Tax Chamber) (the FTT), determining that the respondent company, SEL, was exempt from VAT liabilities, as it was an 'eligible body' within the meaning of Note (1)(b) of Item 1 of Group 6 of Sch 9 to the Value Added Tax Act 1994. The FTT had erred by not addressing the statutory test and had misdirected itself about the proper analysis of the facts. Accordingly, the FTT had been wrong to determine that SEL had been a 'college of' MU.