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DISCUSSION
DISCUSSION
Submissions
In summary Miss Grainger submitted as follows:
Given the agreed extension of time to which the appellant had originally consented, the statement of case had to be submitted by 24 February 2025. The application was made on 21 February 2025. It was therefore made in time so this is not a relief from sanctions case.
The relevant principles are set out in the case of Transports Tresserras v HMRC [2024] UKFTT 538.
- Heading
- BACKGROUND FACTS
- RULE 2
- DISCUSSION
- In the alternative, if this is a relief from sanctions case, the principles are set out in the case of William Martland v HMRC [2018] UKUT 178 (“ Martland ”)
- Accordingly, in HMRC’s view a further extension was required. The application was made on 21 February 2025
- He also wants clarity on the current timetable for this appeal
- Conclusions