“…tention to the power to open an enquiry under section 9A of the Taxes Management Act 1970, as amended, which was considered by this Court in Raftopoulou v HMRC [2018] EWCA Civ 818; [2018] STC 988: see in particular paras. 15 and 41-43 in the judgment of David Richards LJ. I have not found that decision of assistance, concerning as it doe…”