You may find that your outline of the case, prepared beforehand
in the light of facts then known and the contentions expected,
requires radical alteration in order that facts newly elicited or
fresh aspects of the appellant's case brought out may be properly
dealt with.
It is important that you reply adequately to the case for the
appellant as it stands at the conclusion of the evidence given on
his behalf.
When a point is raised unexpectedly by the other side, or
when a new contention is put forward, all the implications of which
are not immediately evident, it may be appropriate to seek an
adjournment so that the new points may be properly dealt with.
Similarly, if you consider that the appellant's case as presented
differs materially from that known to you prior to the hearing, you
should draw this to the Commissioners' attention and request an
adjournment.
This course should only be taken where it appears essential
to do so in the interests of HMRC.
