“…d costs. Furthermore, the relevant appeal provisions, sections 31(1)(b) and (d) of TMA should be read broadly in light of cases like MCX Dunlin (UK) Ltd v HMRC [2021] EWCA Civ 186, [2021] STC 474: the term “assessment” is generic in the tax code, and the analysis applied in that case should apply in respect of every assessment to tax. Th…”