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The Appellant’s complaint to HMRC
The Appellant’s complaint to HMRC
The Appellant’s case overlapped considerably with the formal complaint that it had made on 2 September 2024. Indeed, Mr Chaudhary’s first submission to us was that the Appellant’s submissions to us had been addressed by the response from HMRC’s complaints team on 20 November (a copy of which we were not shown).
We certainly do not wish to trespass on the complaints process which is separate from this Tribunal. However, we recognise that the background facts underlying the complaint are relevant to the Appellant’s appeal before us.
- Heading
- Introduction
- Overview of the case
- The legislative scheme
- The case law on reasonable excuse
- The case law on special reduction
- Findings of fact
- The Appellant’s complaint to HMRC
- Penalty for late payment
- Reasonable excuse
- Discussion
- Special reduction
- HMRC’s arguments
- The Appellant’s arguments
- Discussion
- Conclusions