I got MOR'd by a tower for landing with them off on a dark stormy night with a cloud base of 001 bkn and RVR of 700m and thick snow falling. If you had them on you could barely see 5m past the nose and the glare was effecting my vision. With them turned off it was fine picked up the approach lights at 300ft and had good visual references for the flare. The company never even heard from the CAA asking to justify my actions so I presume it got to the pilot side of things and was stopped there.
The reason you never heard from the CAA is that there is no legal requirement to use landing lights and it's really no business of ATC to try to mandate what other lights are used by a pilot, other than the mandatory ones.
Years ago I returned from Germany to Manston (then RAF) in bad weather, in a recently modified RAF Puma. It had one of the first pilot selectable red / white strobe type anti-collision beacons fitted. As I hover taxied in, the tower controller told me I had a red strobe on. I replied "Roger, thanks" and carried on hover taxying. He then immediately replied "turn off your strobe!" I did. He said "Put your anti-collision light on!" I turned the red strobe back on and he immediately said "TURN OFF YOUR STROBE!" I said: "I'll call you on landing."
After we landed, I rang him up and had a further "discussion", during which I explained that the red strobe he was looking at WAS the ONLY anti-collision light fitted and invited him to come down to the aircraft and show me which "other" switches he would like selected.
