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Four appeals were brought by Weight Watchers (UK) Ltd against assessments raised by HMRC under VATA 1994 s 73.
The appellants’ case was that the four assessments were all made out of time as they were made more than two years after the end of the accounting periods to which they respectively related and more than one year after the date on which evidence of the facts sufficient to justify the making of an assessment came to the knowledge of HMRC (see VATA 1994 s 73(6)).
The fundamental issue was therefore whether ‘evidence of facts sufficient in the opinion of HMRC justify the making of the assessments came to their knowledge’ less than one year before the assessments were made (s 73(6)(b)).
The four notices of...
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