Production of Documents at the Appeal Stage

The Tribunal found that the additional documents the Appellant sought to adduce were critical in assisting the Tribunal towards clarifying the facts of the dispute and in helping the Tribunal in arriving at a just and fair determination. The Tribunal also found that the documents appeared to go to the crux of the Appellant’s challenge to the tax assessment and thus were likely to have an influence on how the Tribunal is likely to reach its decision after the interrogation of such documents.