The CAA answered my question on this matter quite some time ago along with a number of other questions. There view is that training with an Instructor over rides the requirements for self certification. The requirements to carry passengers are self certification i.e they do not require an Instructors sign off. If you have not met the requirements you can either seek training with an Instructor to regain the currency or you can go off and fly the three circuits on your own.
Seems simple enough to me, so I fail to understand why this is being turned into a willy waving contest by you DFC.
It also answered my questions on where an IMCR could be taught from. Care to take a stab at answering that one as well?