Discussion
Discussion
In determining whether permission should be granted to bring an appeal out of time, the Tribunal has applied the three-stage approach endorsed in Martland v HMRC [2018] UKUT 0178 (TCC). The Tribunal must first assess the seriousness and significance of the delay, then establish the reasons for the default, and finally evaluate all the circumstances of the case. In contrast to HMRC, the Tribunal is not restricted to considering whether or not there has been a reasonable excuse for the delay.
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