VAT – appellant exercising option to tax (OTT) for eight years – property in question sold without charging VAT – assessments issued but not appealed – appellant informing HMRC that OTT invalid – HMRC exercising power to deem OTT to be valid – whether right of appeal against exercise of that power –whether HMRC acted unreasonably – whether appellant estopped from relying on earlier meeting with an HMRC officer – held, no right of appeal but in the alternative, appellant estopped and HMRC acted reasonably
Source: bailii.org“
