“… exercise carried out by the FTT in an appeal under section 16(4) of the Finance Act 1994 was considered further in Balbir Singh Gora v Customs and Excise Cmrs [2003] EWCA Civ 525, [2004] QB 93 (‘Gora’). The appeals in Gora arose from the seizure of alcoholic liquor by customs officers who were not satisfied that duty had been paid corre…”
“…. The apparent strictness of this approach has, however, been significantly alleviated by the decision of this court in Gora v Customs and Excise Commissioners [2003] EWCA Civ 525, [2004] QB 93, where Pill LJ accepted the submission of counsel for HMRC (Mr Kenneth Parker QC, as he then was) that the provisions of section 16 do not oust t…”