VALUE ADDED TAX – remittal for retrial by the Upper Tribunal – input tax deductibility – right to deduct restricted under principles in Kittel – article 5 of SPO – purchases and sales of branded Solid State Drives (‘SSD’) and SD Memory Cards – transactions found and conceded to be connected with fraudulent VAT evasion – whether burden on the appellant’s ‘innocence’ as pleaded discharged – whether actual or ‘blind-eye’ knowledge of the transactions being connected with fraud – whether constructive knowledge in the alternative – appeal dismissed
Source: bailii.org