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VAT - penalty for failure to notify liability to be registered for VAT - non deliberate - whether to permit a new ground of appeal - no - whether special circumstances - no - whether reasonable excuse - no - appeal dismissed
For the Respondents: �� Olivia Donovan, litigator of HM Revenue and Customs� Solicitor�s Office
             A summary of this decision was released to the parties on 21 June 2023. GB-Gadgets subsequently applied for this full decision.
              Prior notice of the hearing had been published on the gov.uk website, with information about how representatives of the media or members of the public could apply to join the hearing remotely to observe the proceedings. As such, the hearing was held in public.
             We make the following findings of fact.
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