In Dr R Pandey v HMRC [2017] UKFTT 216 (8 March 2017) the FTT found that HMRC had acted unreasonably in imposing penalties in the absence of loss of revenue.
This was a late appeal by Dr Pandey against penalties imposed under FA 2007 Sch 24 for alleged inaccuracies in a tax return.
Dr Pandey was a paediatric heart surgeon. Her only source of income was her NHS pay which was subject to PAYE. While working in Australia she had received a phone call from HMRC informing her that it considered that she owed £100 000 of tax. She had filed all outstanding returns with the help of an accountant found online. HMRC had subsequently imposed a penalty (under FA 2007 Sch 24) for careless inaccuracies and issued a notice of application for an attachment of earnings order for £53 108.40.
The FTT allowed the late appeal...
