TC09675 - [2025] UKFTT 01274 (TC)

Fecha: 23-Abr-2025

HMRC’s arguments

HMRC’s arguments

28.

HMRC said that the delay of 523 days was serious and significant.

29.

Mrs Sercombe submitted that no good reason had been provided for the delay.

30.

In relation to all the circumstances HMRC:

(1)

Highlighted the need for litigation to be conducted efficiently and at proportionate cost and for statutory deadlines to be respected, relying on Martland and Katib.;

(2)

Submitted that they would be prejudiced if the appeal was allowed to proceed as they would have to divert resources to defend an appeal which they were entitled to consider closed.

(3)

Said simply that the Appellant had a weak case.

(4)

Initially sought to rely on the 31 May 2023 letter to the Company rejecting its ADR application on the basis that there was no appeal before the First-tier Tribunal, as evidence of further material delay by the Appellant in bringing his appeal. However, HMRC later accepted that the Appellant was not aware that he did not have an appeal before the First-tier Tribunal until he spoke to HMRC on 25 August 2025 and did not pursue this point further.