Anandpreet Powar v The Commissioners for HMRC

Facts

The applicant, Mr Anandpreet Powar, was the sole director and sole shareholder of Drinks 4 Less (UK) Limited, a wholesaler of wine, beer, spirits and other alcoholic beverages registered for VAT from 5 September 2011 and registered with HMRC as a High Value Dealer. Following engagements with HMRC, including visits to the company's warehouses, HMRC issued 11 excise assessments against the company for £195,105 on 10 October 2016, upheld on statutory review on 14 February 2017, and a related penalty of £85,358.38 on 22 September 2017 together with a personal liability notice against the applicant under Schedule 41 to the Finance Act 2008. Separately, HMRC denied the company's input tax claims on Kittel grounds, issued a VAT penalty and a further personal liability notice under Schedule 24 to the Finance Act 2008, and refused approval under the Alcohol Wholesaler Registration Scheme. The VAT, excise and AWRS proceedings were consolidated in 2018 and the excise proceedings deconsolidated in 2019; the company withdrew its VAT and AWRS appeals after entering liquidation. The First-tier Tribunal dismissed the applicant's appeal against the VAT personal liability notice in May 2024, and on 9 December 2025 struck out his appeal against the excise duty personal liability notice. Permission to appeal that strike out was granted on grounds 2 and 3 but refused on grounds 1, 4 and 5; the applicant renewed grounds 1 and 4 at an oral hearing.