Additional evidence admitted in appeal, with its reliance left open for determination at the final hearing.

Additional documents not produced before the lower authorities were permitted to be placed on record in the appeal, but their evidentiary reliance and acceptability for deciding the matter were deferred to the final hearing. The note therefore recognises a procedural allowance to supplement the record while preserving the Tribunal's ability to determine, at the merits stage, whether those documents can properly be relied on for adjudication.

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Issues: Whether the Revenue could be permitted to place on record additional documents not produced before the lower authorities, and whether such documents would be relied upon at the stage of final hearing of the appeal.

Outcome: Permission was granted to introduce the additional documents, while their reliance and acceptability for deciding the appeal were left to be determined at the time of final hearing.

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