TC09514 - [2025] UKFTT 00524 (TC)

The appellant requested a statutory review of the decision and in the review conclusion letter dated 20 December 2023 (“the review conclusion letter”) the reviewing officer upheld the decision.

The appellant paid £235,515.93 to HMRC on 17 January 2024. It then made a retrospective claim for steel quota and received £57,330.54 by way of reimbursement (we are not certain when this claim was made, nor the date of reimbursement, but there is evidence suggesting that it was in May 2024). There was insufficient quota available for the relevant period to enable the appellant to make a claim for reimbursement of the entire amount of safeguarding duty.

On 17 January 2024, the appellant also attempted to submit an appeal through the tribunal’s online portal. The notice of appeal generated on 17 January 2024 records that a document was uploaded with its appeal papers, but it is accepted that this was not the review conclusion letter. One reason for this is that in a letter dated 26 January 2024 from the tribunal to Mr Cardey, the tribunal indicated that the appellant had not included, with its notice of appeal, a copy of any written record of any decision appealed against.