Burden of Proof

"For the avoidance of doubt, the tribunal is reminded that in matters where the issue is supply of goods, be it for VAT purposes or Corporation Tax, the burden is always on the trader/taxpayer to show that, the documentation set out in the statute and in which he relies on arose out of a commercial transaction. If additional documents, which would be reasonably expected to be in his possession are requested for to verify the alleged transactions, he should produce the same to the commissioner. That is what is expected of a keen and diligent trader.”