Correct approach?

He was also the director of a company. Both businesses traded from the same premises. The company was VAT registered but the unincorporated business was not.
Following a routine inspection by a Customs official of the books of the unincorporated business it was noticed that the turnover of that business was far greater in the year than it had been on the previous visit. The appellant was therefore advised to register for VAT which he did and was registered with effect from 2 July 1996.
Customs subsequently said that the appellant was liable to a penalty for late registration. The tribunal found in favour of Customs so the appellant went to the High Court.
The appellant argued that he should have been registered from the beginning of September 1996 rather than July as that would have been the end of...