The appellant, Heartlands House Limited, appealed against a decision by HMRC to refuse three input tax repayment claims for the VAT periods 09/19, 06/20 and 09/20.

HMRC had refused the claim as Heartlands had not provided ‘sufficient evidence’ to support the claim that it had made or had the intention to make taxable supplies.

Although Heartlands accepted that the assessments for 06/20 and 09/20 were correct, as the VAT had been claimed in error in respect of purchases relating to exempt suppliers, it argued that the 09/19 assessment for £28,221.96 was valid.

Heartlands provided services in the construction sector, securing projects and using subcontractors to carry out the works.