Looks correct to me.
Outram & Anor v Revenue And Customs (INCOME TAX - discovery assessments) [2024] UKUT 203 (TCC) (15 July 2024) (bailii.org)
https://www.bailii.org/uk/cases/UKUT/TCC/2024/203.html
This shows it's not easy for HMRC to prove deliberate misconduct where there is reliance on a tax advisor with a supporting counsel opinion (even for an aggressive looking tax avoidance scheme). Alternatively, it shows some FTT judges are not too good at explaining their reasoning (properly per the relevant law) in their judgments.
