TC09675 - [2025] UKFTT 01274 (TC)

Case Number: TC09675

By remote video hearing

Appeal reference: TC/2023/09962

Application for permission to make a late appeal to the Tribunal pursuant to section 83G(6) of the Value Added Tax Act 1994 – three stage approach in Martland applied – Katib applied – Medpro approach to weight to be given to ‘compliance’ factors taken stricter Martland approach undertaken as a cross-check – permission refused

Judgment date: 24 October 2025

Before

TRIBUNAL JUDGE ROSA PETTIFER

Between

SHOEB CHOUDHURY

Appellant

and

THE COMMISSIONERS FOR HIS MAJESTY’S REVENUE AND CUSTOMS

Respondents

Representation:

For the Appellant: Mr Huw Shepheard of counsel, instructed by H Accountancy Ltd

For the Respondents: Mrs Heather Sercombe litigator of HM Revenue and Customs’ Solicitor’s Office

DECISION