“…wers by way of “inherent jurisdiction” (as regards the Upper Tribunal see, most recently, BPP Holdings v Her Majesty’s Revenue and Customs [2016] EWCA Civ 121, [2016] 1 WLR 1915, per Ryder LJ at para. 25 (p. 1923)); and in Akewushola v Secretary of State for the Home Department [1999] EWCA Civ 2099, [2000] 1 WLR 2295, Sedley LJ, albeit…”
“…e should not be applied in the context of VAT proceedings in the FTT was overturned by this Court in BPP Holdings LtdvHM Revenue & Customs [2016] EWCA Civ 121, [2016] 1 WLR 1915, that decision being upheld by the Supreme Court ([2017] UKSC 55, [2017] 1 WLR 2945).…”