|Source:||All England Reporter|
|Publisher Citation:|| All ER (D) 63 (May)|
Peter Leaver QC sitting as a deputy judge of the High Court
|Representation||David Chivers QC and Michael Patchett-Joyce (instructed by The Khan Partnership) for the claimant.|
|Philip Moser QC (instructed by the Solicitor for the Revenue and Customs Commissioners) for the Revenue.|
|Judgment Dates:||27 April 2012|
Set-off - Assignment of debt - Taxation - Claimant being assigned company's benefit of appeal against disallowance of VAT input tax - First-tier Tribunal awarding claimant VAT input tax - Respondent Revenue and Customs Commissioners seeking to set-off award against tax owing by company - Claimant submitting no right to set-off - Claimant submitting legitimate expectation award not being set-off - Claimant seeking interest on award - Whether Revenue being entitled to set-off - Whether claimant having legitimate expectation award not being set-off - Whether claimant being entitled to interest - Tribunal, Courts and Enforcement Act 2007, - Finance Act 2008, ss 130, 133.