TC09523 - [2025] UKFTT 00544 (TC)

With the consent of the parties, the form of the hearing was by video and attended by all participants remotely on the Teams video hearing system. The documents to which the Tribunal (“we/the tribunal”) were referred to were contained in a Joint bundle of documents comprising of 298 pages, a further three supplementary bundles of 5,9 and 2 pages respectively, an Authorities Bundle of 138 pages and Skeleton Arguments from both parties.

Prior notice of the hearing had been published on the gov.uk website, with information about how representatives of the media or members of the public could apply to join the hearing remotely to observe the proceedings. As such, the hearing was held in public.

Applications on behalf of the Applicant/Appellant, Ved Parkash (“the Appellant/VP”), were made by email on 28 March 2024, and followed up by a letter in similar terms on 1 April 2024.

The applications are (1) for relief from the failure to make an application within 28 days of an order dated 15 January 2024 (“the Strike Out Order”) following the failure to comply with a Direction (“the Unless Order”) made on 19 December 2023, (“the Time Limit application”) and (2) to have VP’s appeal reinstated (“ the Reinstatement application”) under Rules 8(6) and 8(5), respectively, of the Tribunal Procedure (First-Tier Tribunal) (Tax Chamber) Rules 2008 (“the Tribunal Rules”).

The amount of the assessment which is the subject of the appeal is thought to be in excess of £1 million but the quantum may be different depending on whether assessments in relation to the period prior to the declaration of VP’s bankruptcy in 2010 are or are not included. The figure detailed in a letter by VP’s accountant, Roshon Singh (“RS”), of ABC, Accounting Business Consultants (“ABC”), to HMRC on 08 February 2024 referred to £598,063.90 against which VP asked HMRC to consider a full and final settlement offer of £300,000 to bring the matter to closure.

HMRC objected to both applications.

Sece Appendix A.

See Appendix B.