“…ceedings appealed the UT’s decision to this court, which handed down judgment in April 2014: British Telecommunications plc v Revenue and Customs Commissioners [2014] EWCA Civ 433, [2014] STC 1926 (“BT CA”). Following a reference to the CJEU in the GMAC proceedings, an appeal in that case was heard later, in 2016: GMAC v Revenue and Cust…”
“…“[I] agree with the decisions of the UT and this court in [The Commissioners for Her Majesty's Revenue and Customs v British Telecommunications PLC [2014] EWCA Civ 433] that there is no room in the context of the present case for the imposition of a time limit by reference to the EU reasonable time rule. Such time limits as a…”