“ The background to the Notice and the issue in the case 9. The background to the Notice was not in dispute. HMRC had opened an enquiry into Mr Singh’s 2005-06 tax return, and in the course of that enquiry identified sums totalling£13,415 which had been paid into Mrs Kaur’s Nottingham Building Society and RBS bank accounts. Mrs Kaur is Mr Singh’s wife. The Notice related to the payments made into those accounts. … 15. In addition to the correspondence, the Bundle also contained the following documents: … (2) Bank statements with the same account holder as the individuals listed on the summary of cash receipts (“the Bank Statements”). Each Bank Statement was redacted, leaving en clair only the name of the bank, the name of the account holder and a sum of money which matched the “cash 5 withdrawn” figure for that payee on the summary of cash receipts.”
“23. The reason for the extensive redaction of the Bank Statements was that the payees did not want their details to be provided to HMRC. Mr Singh had had to ask the leaders of his Sikh temple to assist him in persuading the payees to provide the Bank Statements. Following that intervention, the payees did provide the Bank Statements but on condition that their addresses were not disclosed to HMRC; this was in order to protect their privacy. 24. The Tribunal asked Mr Singh whether all the payees were Sikh and he said no, some were not, but once the Sikhs had agreed to provide their Bank Statements, the others agreed to follow suite, on the same basis.”
“39. Turning to the question of addresses, he accepted this was “more difficult”
“45. We thus find that it is reasonable for HMRC to seek further evidence of the link which Mr Singh says exists between these payees and the money in Mrs Kaur’s accounts. HMRC’s request for the full postal addresses of each of the payees is confirmed, albeit slightly varied to avoid ambiguity and provide further clarity. The varied Notice is set out at the end of this decision.”
“ The Notice 47. Under Sch 36, para 32, the Tribunal varies the Notice issued on25 April 2012 . 48. We rephrase item 1 of the Notice so that it reads as follows: “Please provide a schedule showing the full current postal addresses of all the individuals you say provided loans and/or gifts of money to you in the period from 6/4/05 to 5/4//06. For the avoidance of doubt, you must also provide to HMRC a further copy of each and every third party bank statement already submitted by you to HMRC, with the full unredacted postal addresses shown clearly on every such statement and without any redaction of the information already provided.” 49. We delete item 2 of the Notice, so that Mr Singh does not have to provide information about his relationship with each of the individual payees. 50. Under Sch 36, para 32(4) we specify that Mr Singh must 5 comply with the Notice as varied by the Tribunal, ie as set out in the bold text above, so as to provide this information to HMRC no later than one calendar month from the date of issue of this decision. No right of appeal 51. Under Sch 36, para 32(5) this decision is final and there is no right of appeal.”