“…The correct approach to appeals against case management decisions is well established. HMRC relied on Sales J’s summary in HMRC v Ingenious Games LLP [2014] UKUT 0062 (TCC), [2014] STC 1416 (“Ingenious Games”) at [56], which was also referred to by the UT:…”
“…sion with which the UT should not interfere if the FTT had applied the correct principles in exercising its discretion, referring to HMRC v Ingenious Games LLP [2014] UKUT 0062 (TCC) (a different Ingenious case) at [56]. They referred to Rules 2, 5, 15, 25 and 27 of the FTT Rules. They held that the FTT was entitled to take the view that th…”