“…implied power would be convenient or desirable is not sufficient (see Hazell v Hammersmith and Fulham LBC [1992] 2 AC 1 at [31]; R(OAO ABC Ltd) and Anor v HMRC [2018] 1 WLR 1205 at [47]-[48]). He contends that Nugee J was wrong to reject the appellants’ submission that using the…”
“…y had put before the court by the time of the eventual compromise. For this purpose it is necessary to refer to the Court of Appeal’s decision in the ABC case: [2018] 1 WLR 1205. The court held that HMRC did have a statutory power to admit a trader to the register on a temporary basis pending the determination of an appeal against the …”
“…Act 2015. The history and operation of the AWRS were described in detail by this court in R (ABC Ltd ) v Revenue and Customs Commissioners [2017] EWCA Civ 956, [2018] 1 WLR 1205. Part 6A makes the selling of liquor wholesale on or after the point at which excise duty is payable a controlled activity. Section 88C ALDA prohibits a busine…”