Re: Ignorance of the law is not a defence...
I’ve partly changed my mind on the above, but only because I’ve spent the last 2 hours reading up on the workings of the First Tier Tribunal. It looks like right to trial by a jury of your peers has been abandoned for tax cases. I think that there is sufficient case for Aria to appeal due to the tribunal being incorrect on a point of law, but, I feel that only companies or persons with large enough pockets could afford to go down this route.
TLDR: the law it appears has been changed in favour of HMRC process because it appears the courts are too dumb to understand all these complex tax rules, and heck, HMRC must know what it is doing because it makes the rules, so simples!