“…s in judicial review proceedings, but none of the challenges had been successful. Apart from Rowe, the cases to which the judge referred were R (Walapu) v HMRC [2016] EWHC 658 (Admin), R (Dickinson) v HMRC [2017] EWHC 1705 (Admin), [2017] 4 WLR 126, and the decisions of the High Court and this court in relation to what the judge called a “si…”
“…ordered; (ii) HMRC had succeeded in resisting challenges to APNs in three cases (Rowe & ors. v HMRC [2015] EWHC 2293 (Admin) (Simler J) (“Rowe”); Walapu v HMRC [2016] EWHC 658 (Admin) (Green J, as he then was) (“Walapu”) and his own decision in Vital Nut v HMRC [2016] EWHC 1797 (Admin) (“Vital Nut”); and (iii) the court should not second gue…”