NG International v HMRC [2012] UKUT 259 (24 July 2012)
"VAT – MTIC – whether First-tier Tribunal misdirected itself on the meaning of the "only reasonable explanation" test and took too broad an approach – Kittel – Mobilx – whether trader should be prevented from relying on the legality of his transactions only to the extent that, had he conducted perfect due diligence on his suppliers, such due diligence would have indicated the fraud – Livewire considered – alleged reliance by trader on representations made by HMRC".
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