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Income tax – Information notice. The First-tier Tribunal (Tax) (the FTT) granted the defendant Revenue and Customs Commissioners' (the Revenue) application for third party information and document notices, under para 2 of Sch 36 to the Finance Act 2008. The claimants sought judicial review of the Revenue and the FTT's decisions. The Administrative Court, in dismissing the application, held that the giving of the notices had not been invalid due to a failure to give reasons or the giving of inadequate and late reasons. Further, there had been no breach of art 6 of the European Convention on Human Rights when taken in conjunction with art 8 of the Convention and/or art 1 of the First Protocol to the Convention.
Income tax – Information notice. The First-tier Tribunal (Tax) (the FTT) granted the defendant Revenue and Customs Commissioners' (the Revenue) application for third party information and document notices, under para 2 of Sch 36 to the Finance Act 2008. The claimants sought judicial review of the Revenue and the FTT's decisions. The Administrative Court, in dismissing the application, held that the giving of the notices had not been invalid due to a failure to give reasons or the giving of inadequate and late reasons. Further, there had been no breach of art 6 of the European Convention on Human Rights when taken in conjunction with art 8 of the Convention and/or art 1 of the First Protocol to the Convention.
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