The Appellant having documents to support its averments, discharged its burden of proof.

“However, the above listed documents have been provided by the Appellant to support its averments that the non-income items were part of its banking, and should not be treated as income for corporation tax purposes …The Appellant having documents to support its averments, discharged its burden of proof, and the onus lies on the Respondent to review the documents provided in making a decision as to what tax liability sits with the Appellant. Due to the foregoing, it is clear to the Tribunal that the income computed by the Respondent in establishing the Appellant’s corporation tax liability should be adjusted to exclude non-income amounts.”