1 Broadly, s 167 of the ITAA 1936 provides that if a person fails to lodge a return or the Commissioner is not satisfied with the return lodged or the Commissioner has reason to believe that any person who has not lodged a return has derived taxable income, the Commissioner may make an assessment of the amount upon which in his or her judgement income tax ought to be levied and that amount shall be the taxable income of that person for the purpose of s 166 of the ITAA 1936 which, in turn, provides for assessments to be made by the Commissioner.

2 Since the filing at the AAT of the application for review, the Administrative Review Tribunal (Tribunal) has been established by the Administrative Review Tribunal Act 2024 (Cth) (ART Act). Broadly, transitional provisions under the Administrative Review Tribunal (Consequential and Transitional Provisions No. 1) Act 2024 (Cth) provide that unfinalised proceedings in the AAT must be continued and finalised by the Tribunal in a manner that is efficient and fair. No practical issue arises from the AAT being replaced by the Tribunal.

1. It is clear from Mr Palmer's Statement of Facts, Issues and Contentions (SFIC) dated 1 October 2024 that he considers there are a myriad of different issues for determination by the Tribunal at the final hearing. Mr Palmer has stated that "Issue 1" concerns the following:

Is there an obligation, at law, for the Applicant to prove that the default assessments are excessive? Does the Applicant actually have to prove what his 'taxable income' is - if, indeed, he even has a taxable income - or, in the Constitutional Monarchy in which we live, is the onus actually on any entity making the claim (in particular, a claimed government entity, purporting to operate under the ultimate authority of some law/act, legislation within the Commonwealth of Australia)

1. Mr Palmer has stated that "Issue 2" is whether he is "liable to pay administrative penalties when penalties can only be lawfully imposed by a court of competent jurisdiction?" and, furthermore, "Issue 3" is "how did [Mr Palmer] become a 'taxpayer'?" With respect to the latter issue, Mr Palmer claims that the onus is on the Commissioner to prove that Mr Palmer is, in fact, a taxpayer according to law and, therefore, that the taxation law applies to him. It is unnecessary for present purposes to refer to the other issues which Mr Palmer has raised. It suffices to note that all of the issues raised by Mr Palmer are unorthodox.

1. Mr Palmer has stated the following under the heading 'Facts' regarding himself in his SFIC:
   1. [Mr Palmer] is a living breathing man, a de jure solemn et naturale. This entity is not referred to in any of the legislation relied upon by the [Commissioner].
   2. [Mr Palmer] is not a resident of Australia, he is a resident of his body and is merely domiciled in Australia.
   3. [Mr Palmer] is a subject of the Crown, as defined by the Commonwealth of Australia Constitution Act 1900 (UK). That entity is not referenced by any of the legislation relied upon by the Respondent.
      1. By the ATO's own definition of a 'taxpayer', [Mr Palmer] does not fit the definition.

[Mr Palmer's] labour produces outcomes, not incomes.

1. For his part, the Commissioner identified in his SFIC dated 13 August 2024 that there are essentially two broad categories of issues: first, regarding the s 167 [of the ITAA 1936] default assessments and, secondly, the assessments of administrative penalty. With respect to the default assessments, the Commissioner states the issue is whether Mr Palmer has discharged his onus to prove that the assessments were excessive and what they should have been by proving, as a matter of evidence, what was his actual taxable income in each of the Relevant Years, not by demonstrating that there was some error in the Commissioner's approach in making the assessments. The Commissioner expressly

stated in his SFIC that he relied on s 14ZZK of the TAA and put Mr Palmer to proof on all facts upon which he seeks to rely to establish that the assessments are excessive.

1. The Commissioner also relevantly stated in his SFIC that at all times during the Relevant Years Mr Palmer was an Australian resident for income tax purposes and identified his residential address. He also stated that Mr Palmer had not lodged an income tax return in respect of each of the Relevant Years. The Commissioner further stated that, after finalising his audit of Mr Palmer's tax affairs, he issued Mr Palmer with s 167 default assessments of income tax for each of the Relevant Years and, additionally, assessments of administrative penalties. On 1 February 2024, notices of amended assessments had been issued to Mr Palmer for the financial years ended 30 June 2015 and 2016.

1. On 16 July 2025, Mr Palmer requested the issue of a summons to the Respondent to produce documents, in the following terms:

All documents and/or information, whether in electronic or hardcopy form, that the Commissioner of Taxation relied on to ascertain that the Applicant, Michael Gareth Palmer, was described in the tables, or covered by the subsections, of the Legislative Instrument issued under, or pursuant to, section 161 of the Income Tax Assessment Act 1936 for the financial years 1 July 2007 to 30 June 2016, as a person required to give a return to the Commissioner for the income years 2008 through 2016.

1. In the Request to Issue Summons form accompanying the abovementioned First Summons Request, Mr Palmer stated, amongst other things, that at all material times during the Relevant Years, he was not a resident of Australia for the purposes of the ITAA 1936 nor did he do any act to cause himself to be described in any of the applicable legislative instruments as a person required to give tax returns to the Commissioner. Accordingly, Mr Palmer stated that the Commissioner did not have authority to issue the default assessments under s 167 of the ITAA 1936 nor the related assessments of penalties. Moreover, he submitted that the issue of the assessments was a separate act of maladministration, to which s 175 of the ITAA 1936 did not apply. Section 175 states that "[t]he validity of any assessment shall not be affected by reason that any of the provisions of [the ITAA 1936] have not been complied with".
2. Notwithstanding, Mr Palmer submitted that in view of the Commissioner having made the assessments, he now sought disclosure of documents and/or information from the Commissioner which showed what the Commissioner relied on to identify that Mr Palmer is required by the relevant legislative instruments to give a return for each of the Relevant Years to the Commissioner. The legislative instruments referred to are those issued by the Commissioner regarding the lodgement of returns for each financial year in accordance with s 161 of the ITAA 1936, and which specify the persons required to lodge returns.

1. In his affidavit sworn on 17 July 2025 in support of his First Summons Request, Mr Palmer relevantly deposed as follows:
   1. I have obtained a copy of, and read through, each of the Legislative Instruments issued by the Commissioner of Taxation under, or pursuant to, section 161 of the Income Tax Assessment Act 1936 for the income years enumerated from 2008 to 2016 [the Assessment Years].

1. I have carefully considered these Legislative Instruments to ascertain what documents and/or information could be relied on to identify a person required to give a return to the Commissioner for the Assessment Years.

1. After conducting a thorough examination of my documents and records, located both in Australia and overseas, relating to my financial affairs, I have located no document or information that would cause me to be described in any table, or covered by any subsections, of any of the Legislative Instruments relative to the Assessment Years.

1. l have also carefully considered my conduct from the commencement of the Assessment Years up to the time of the making of this affidavit, and to the best of my knowledge and beliefs, I have not engaged in any conduct or act that would cause me to be described in any table, or be covered by any subsections, of a Legislative Instrument issued by the Commissioner of Taxation under, or pursuant to, s.161 of the Income Tax Assessment Act 1936 for any of the Assessment Years.

1. In addition, l have not, to the best of my knowledge or beliefs, engaged in any conduct or act that would cause me to be a resident of Australia for the purposes of the Income Tax Assessment Act 1936.

1. On 6 August 2025, Mr Palmer filed a hearing certificate with the Tribunal indicating that he wished to cross-examine the Commissioner of Taxation at the final hearing scheduled to take place in early December 2025 (Second Summons Request).
2. On 11 August 2025, the Commissioner advised Mr Palmer that he was not calling any witnesses and, therefore, the "Commissioner of Taxation" would not be made available for cross-examination.

The Interlocutory Hearing, the Subsequent Submissions and Correspondence

1. At the interlocutory hearing on 12 August 2025 addressing Mr Palmer's First Summons Request and Second Summons Request, Mr Palmer resiled slightly from his earlier position for the Commissioner to attend, and indicated that the individual taxation officers involved in making the default assessments should alternatively be summonsed to give evidence at the final hearing.

1. Mr Palmer filed lengthy written submissions dated 11 August 2025 in support of his position. At the request of the parties at the interlocutory hearing, I granted leave for the Commissioner to file submissions by 15 August 2025 and for Mr Palmer to file reply submissions by 22 August 2025. Both parties filed submissions accordingly. In total, Mr Palmer filed approximately 34 pages of written submissions and the Commissioner filed 5 pages.

1. On 28 August 2025, the legal representatives for the Commissioner wrote to Mr Palmer in the following terms, with a copy to the Tribunal:

We have identified a number of indicators that suggest you may have used a large language model (LLM) (also referred to as "generative AI") in the preparation of your Submissions... It appears to us that your Submissions are, whether in whole or in part, a product of an LLM, as cases and legislation are cited throughout for propositions that they do not stand for, or for which incorrect quotations are provided.

We are concerned that you have not disclosed this use to the Tribunal and do not appear to have checked the output of the LLM for accuracy before filing your material.

What is more concerning is that we have been unable to locate the following authorities referred to in your Submissions:

In view of the above, we request that you urgently check the citations in your Submissions to notify the Tribunal of any corrections required to citations or quotations relied upon. Alternatively, we invite you to withdraw your Submissions to the extent they rely on authorities that do not exist.

1. On 29 August 2025, the Tribunal wrote to Mr Palmer to give him an opportunity until 5pm on 1 September 2025 to respond and notify the Tribunal of any corrections. On that day, I also decided not to publish my decision which had been prepared for publication. On 1

September 2025, a response was received from Mr Palmer by the Tribunal to the effect that several case citations were inadvertently incorrect and he, accordingly, withdrew reliance on those cases. In addition, he sought to replace them with High Court and Full Federal Court authorities and claimed the substance of his arguments was unchanged.

THE RELEVANT STATUTORY PROVISIONS AND PRINCIPLES

Part IVC Proceedings and the Role of the Tribunal

1. The statutory provisions and principles relevant to Tribunal reviews of taxation decisions are concisely set out in s 14ZZK in Part IVC of the TAA, which relevantly states that the applicant has the burden of proving - if the taxation decision concerned is an assessment - that the assessment is excessive.4 It also states that, in any other case the applicant has the burden of proving that the taxation decision concerned should not have been made or should have been made differently.

1. The legal principles applicable to the onus in the context of review of default assessments issued under s 167 of the ITAA 1936 were helpfully summarised by Derrington J in Commissioner of Taxation v Ross [2021] FCA 766; (2021) 174 ALD 77 at [48]. Specifically, his Honour observed at [48(9)], as follows:

The ultimate question in Part IVC proceedings relating to an assessment made under s 167 is whether the amount of the assessment is excessive. That places no burden on the Commissioner to show that the assessments were correctly made: Dalco at 623-624. The manner in which the taxpayer can discharge the burden may vary with the circumstances but "absent agreement with the Commissioner to confine the issues for determination in a Pt IVC proceeding, the Commissioner is entitled to rely upon any deficiency in the taxpayer's proof of the excessiveness of the amount assessed in seeking to uphold the assessment": Gashi [61].

1. In Pratten and Commissioner of Taxation [2025] ARTA 161 (Pratten) at [37]-[40], I stated as follows:
   1. The law is well established as to the Tribunal's role in Part IVC proceedings, as follows. First, the Tribunal engages in de novo merits review, within the confines of a taxpayer's grounds of objection. ...
   2. The Tribunal's role has its foundation in s 9 of the Administrative Review Tribunal Act 2024 (Cth)...

4 See Gashi v Commissioner of Taxation [2013] FCAFC 30 at [61] (Bennett, Edmonds and Gordon JJ) citing Federal Commissioner of Taxation v Dalco (1990) 168 CLR 614 at 623 (Brennan J).

1. Secondly, the Tribunal's task is to make the "correct or preferable decision in relation to the proceeding" and "achieve the objective in section 9" ... Significantly, the effect of s 14ZZK of the TAA is that, by virtue of s 14ZZA of the TAA, the powers of the Tribunal are modified in relation to a review of a taxation decision. Jagot J explained in in Rawson Finances Pty Ltd v Commissioner of Taxation [2013] FCAFC 26; (2013) 296 ALR 307 at [116] the Tribunal's task in taxation review proceedings, as follows:

In a case where s 14ZZK(b)(i) of the TA Act applies the correct or preferable decision is to set aside the decision under review if the applicant has discharged the burden of proving that the assessment is excessive and to dismiss the review application if the applicant has not discharged that burden. The fact that the Tribunal cannot be satisfied that the Commissioner's assessments represent the correct or preferable decision does not mean that the applicant must succeed and the Commissioner fail. This would involve not only the casting of an onus of proof on the Commissioner but would also relieve the applicant of the applicant's burden of proof. Both would be impermissible.

1. Therefore, it is for the taxpayer to disprove the basis of assessment by establishing, amongst other things, the relevant facts. It is not for the Commissioner to prove anything, nor for the Commissioner to place the relevant facts before the Tribunal. It also follows that no part of the Tribunal's function involves the Tribunal reviewing how, or on what basis, the Commissioner made the amended assessments and the objection decisions. The Commissioner's processes are not able to be investigated in proceedings before the Tribunal and are, therefore, completely irrelevant to what the Tribunal must decide.

1. It is also worth noting that the burden of proof is not discharged "by showing error by the Commissioner in the evidentiary, factual or legal basis of assessment"5. This is because it is accepted that in making a default assessment, the Commissioner is required only to make a genuine estimate.6

Decision-maker's obligation to give Tribunal additional documents

1. Before addressing s 74 of the ART Act and the power to issue a summons, it is necessary to briefly address what often emerges as a related issue when an applicant seeks a summons directed to the respondent decision-maker. This is because ss 23, 25-26 of the ART Act generally provide for the provision of documents by the respondent decision-maker.

1. Broadly, s 23 of the ART Act requires the decision-maker to, amongst other things, give the Tribunal documents that are in the decision-maker's possession or control and relevant to

5 Zappia v Commissioner of Taxation [2017] FCAFC 185 at [3] (Pagone J).

6 R v Deputy Commissioner of Taxation (WA); ex parte Briggs [No 2] (1987) 14 FCR 249 (Briggs) at 270.

the Tribunal's review of the proceedings within 28 days of being notified of an application for review of a decision. Section 25 of the ART Act provides that if at any time during the Tribunal's review of a decision, a document that is relevant to the review comes into the decision-maker's possession or control, and the document has not already been given to the Tribunal, the decision-maker is required to give a copy of the document to the Tribunal within 28 days.

1. Additionally, and most importantly where an applicant considers that the respondent has not filed all relevant documents with the Tribunal, the applicant can make an application to the Tribunal for supplementary documents to be filed. Section 26 of the ART Act generally provides that if the Tribunal is satisfied that a document may be relevant to the review is in the possession or under the control of the decision-maker, the Tribunal may request the decision-maker to give a copy of the document to the Tribunal.

1. Having regard to the above statutory provisions which provide a framework for the respondent to provide documents, the Tribunal observes that it is generally not appropriate for parties to use the summons power to obtain documents from the parties themselves. The summons power should generally be reserved to obtain documents from third parties.7

1. Irrespective, as s 9 of the ART Act requires the Tribunal to pursue an independent mechanism of review that is fair and just and, amongst other things, ensures that applications are resolved as quickly and with as little formality and expense as a proper consideration of the matters before the Tribunal permits, it is also appropriate for the Tribunal to be pragmatic and efficient, in appropriate situations such as where the applicant is unrepresented and the use of the summons power would not be disadvantageous.

1. Accordingly, it was on this basis I chose to deal with Mr Palmer's applications for the summons under s 74 of the ART Act rather than request him to make another application under s 26 of the ART Act and file further submissions with respect to the latter. The parties did not object to this course. It should also be recorded that the Commissioner did not seek to take any procedural point and that I canvassed the issue of the appropriateness of the issue of the summons power. For completeness, I note that the Commissioner submitted that he had filed all documents he considered to be relevant to the proceedings pursuant to

7 See Re Radge and Commissioner of Taxation [2007] AATA 1317; (2007) 95 ALD 711 at [78] and ACN 154 520 199 Pty Ltd and

Commissioner of Taxation [2018] AATA 2404 at [16].

former s 37(1) of the AAT Act (relevantly similar to s 23 of the ART Act). The Commissioner further contended that the documents and information sought by Mr Palmer are not relevant to the review and that there was also no basis for the Tribunal to request those documents and information pursuant to s 26 ART Act.

1. In relation to the powers of the Tribunal to issue summonses to give evidence and produce documents, s 74(1) of the ART Act states:

(1) If the Tribunal has reasonable grounds to believe that a person has information, or a document or thing, relevant to a proceeding in the Tribunal, the Tribunal may, in writing, summon the person to do either or both of the following, on the day, and at the time and place, specified in the summons:

(a) appear before the Tribunal to give evidence;

(b) produce any document or thing specified in the summons.

1. Similar to the former s 40A(1) of the now repealed Administrative Appeals Tribunal Act 1975 (Cth) (AAT Act), the word "may" in s 74(1) of the ART Act imports a discretionary power on the Tribunal to decide whether to issue the summons or to refuse the application. It is for the Tribunal to decide who should be summonsed to give evidence and produce documents

1. As I explained in Pratten at [47]-[51], s 74(1) of the ART Act contains some differences to its predecessor statutory provision referred to above. In particular, s 74(1) of the ART Act now expressly includes the condition that "the Tribunal has reasonable grounds to believe that a person has information, or a document or thing, relevant to a proceeding in the Tribunal". Regardless, the principles developed by the courts in relation to the issue of subpoenas continue to provide useful guidance to when summonses are to be issued by the Tribunal. Significantly, a party who seeks the issue of a subpoena "bears the onus of demonstrating that the subpoena has a legitimate forensic purpose in relation to the issue in the proceedings".8

8 Wong v Sklavos [2014] FCAFC 120 at [12] (Jacobson, White and Gleeson JJ). See also Seven Network (Operations) Ltd v Fairfax Media Publications Pty Ltd [2023] FCAFC 185 at [37] (Wheelahan, Anderson and Jackman JJ)

SHOULD THE SUMMONSES BE ISSUED TO THE COMMISSIONER TO PRODUCE DOCUMENTS AND FOR THE COMMISSIONER OR TAXATION OFFICERS TO ATTEND THE HEARING?

1. Mr Palmer argued that he was seeking the documents from the Commissioner to show that the Commissioner had not satisfied himself of a "precondition" to issuing him with default assessments pursuant to s 167 of the ITAA 1936. Mr Palmer claimed that the Commissioner had not established, as "a jurisdictional fact", that Mr Palmer was a resident of Australia and required by a legislative instrument under s 161 of the 1936 Act to lodge a return for the Relevant Years.

1. Mr Palmer argued that "the statutory precondition is not simply 'non-lodgement', but the existence of a legal requirement to lodge in the first place. Unless, and until, the [Commissioner] discharges its burden by producing the actual legislative instruments and showing their application to [Mr Palmer], the s 167(a) gateway cannot be validly enlivened". Mr Palmer, therefore, argued that the foundational question was whether he was lawfully required to lodge a tax return and that the Commissioner had to prove this "before any valid default assessment power could arise".

1. Mr Palmer further argued that "it is essential that the [Commissioner] identify, and the Commissioner be summoned to give evidence of, the actual material said to have been relied upon in forming the belief under s 167(c). Without such disclosure, the Tribunal cannot be satisfied that the statutory gateway was lawfully enlivened." He further argued that there is "before the Tribunal a complete evidentiary vacuum as to the formation of any belief [by the Commissioner] under s 167(c)."

1. With respect to s 175 of the ITAA 1936, Mr Palmer argued that "it does not validate assessments that are devoid of rational or logical foundation" and that s 175 therefore does not cure shortcomings in "statutory preconditions such as residency."

1. Mr Palmer submitted that his requests for the summons to be issued to the Commissioner to produce documents and attend the hearing for cross-examination were proper and not speculative. He said he sought "to clarify the precise statutory basis under s 167 of the ITAA 1936 upon which the Commissioner relied to issue the assessments, and the factual material underpinning that reliance."
2. I agree with the Commissioner's position that the summonses should not be issued by the Tribunal for several reasons. First and foremost, Mr Palmer failed to persuade me that the documents and information sought by him are relevant to the proceedings. The submissions made by Mr Palmer about the relevance of the documents and the information were based on entire misunderstandings about the nature of Part IVC proceedings and the Tribunal's role.

1. It is no part of the Tribunal's function to review how or on what basis the Commissioner issued the default assessments, including under which paragraph of s 167 of the ITAA 1936. The Commissioner's processes, including his audit activities in arriving at the default assessments cannot be scrutinised in Part IVC proceedings in the Tribunal and are, therefore, completely irrelevant to what the Tribunal must decide at the final hearing.

1. The Tribunal's role is to engage in a de novo merits review and to make the correct or preferable decision. As stated above, s 14ZZK of the TAA places the burden of proof on Mr Palmer to demonstrate that the default assessments issued under s 167 of the ITAA 1936 are excessive and what was his taxable income in each of the Relevant Years. Relevantly, in Commissioner v Ross [2021] FCA 766; (2021) 174 ALD 77, Derrington J explained at [48(9)] as follows:

The ultimate question in Part IVC proceedings relating to an assessment made under s 167 is whether the amount of the assessment is excessive. That places no burden on the Commissioner to show that the assessments were correctly made The manner in which the taxpayer can discharge the burden may

vary with the circumstances but "absent agreement with the Commissioner to confine the issues for determination in a Pt IVC proceeding, the Commissioner is entitled to rely upon any deficiency in the taxpayer's proof of the excessiveness of the amount assessed in seeking to uphold the assessment" ...

1. The Tribunal's role was also explained by Jagot J, (as her Honour then was) in Rawson Finances Pty Ltd v Commissioner of Taxation [2013] FCAFC 26; (2013) 296 ALR 307 at [116] as set out above in [22].

1. Moreover, it is abundantly clear from longstanding authorities that the Commissioner is entitled to issue default assessments under s 167 of the ITAA 1936 under any of the three alternative paragraphs provided in that section. The Commissioner is able to exercise his judgment to arrive at a figure upon which income tax ought to be levied even if the

Commissioner is not in possession of all relevant information and even if the Commissioner is aware that the figure is inexact and incorrect, provided that a genuine attempt is made.9

1. Once the Commissioner has arrived at the figure upon which income tax ought to be levied10, which it is acknowledged may be incorrect, s 175 of the ITAA 1936 provides for the validity of the assessment even if any of the provisions of the ITAA 1936 have not been complied with. Moreover, production of the assessments is, relevantly, conclusive evidence that they were properly made with the consequence that internal deliberations of the taxation officers in making the assessments are irrelevant to the Tribunal's role in determining the issues in the proceedings: s 350-10(1), Item 2, Schedule 1 of the TAA.

1. It is s 175A of the ITAA 1936 which provides the taxpayer with review rights as it provides that "[a] taxpayer who is dissatisfied with an assessment... may object against it in the manner set out in Part IVC of the [TAA]". As stated above, Mr Palmer invoked his review rights, objected against the assessments and the Commissioner subsequently made objection decisions in respect of which Mr Palmer has lodged applications for review for the Tribunal to decide.

1. Finally, Mr Palmer argued that his application for the issue of summons was not directed at challenging the validity of the default assessments. However, it was clear from Mr Palmer's arguments, including what is set out above, that he cavilled with the validity of the default assessments and sought the issue of the summonses for ulterior purposes.11 The difficulty for Mr Palmer is that the Tribunal exercises administrative, not judicial power in undertaking a merits review and, as has been repeatedly stated, is not empowered to review the audit process nor the validity of the assessments.12 Accordingly, Mr Palmer's submissions are entirely misconceived and neither the First Summons Request nor the Second Summons Request should be acceded to, as the summonses were not for a legitimate forensic purpose.

10 See s 166 of the 1936 Act which provides that the Commissioner must make an assessment of the amount of taxable income of the taxpayer and the amount of tax payable thereon.

11 See also the Applicant's Reasons for the Request to Issue Summons Form dated 16 July 2025 and affidavit in support sworn on 17 July 2025.

1. It is important to also note that although Mr Palmer cited numerous cases for his abovementioned arguments in his submissions, they did not stand for the propositions he put to the Tribunal, even after his response was received on 1 September 2025 (see [19] above). As a party to Tribunal proceedings, Mr Palmer is obligated under s 56(2) of the ART Act to use his best endeavours to assist the Tribunal to achieve the objective in s 9 of the ART Act. In the circumstances, it would have assisted the Tribunal if Mr Palmer had disclosed at the outset if he had used generative AI to draft his written submissions. It is essential that all parties take care in checking submissions for accuracy before giving them to the Tribunal as every party bears responsibility for the reliability of their submissions.

1. For the reasons given, Mr Palmer has not persuaded me that the issue of the summonses are for a legitimate forensic purpose. His applications for the issue of summonses are, therefore, dismissed.

I certify that the preceding 47 (forty-seven) paragraphs are a true copy of the reasons for the decision herein of Deputy President G Lazanas

......................[SGD].................................................

Associate

Dated: 2 September 2025

Date final submissions received: 1 September 2025

Solicitors for the Respondent: Mr J Tsianikas, Australian Government