TC09593 - [2025] UKFTT 00892 (TC)

This appeal was brought by way of a Notice of Appeal dated 15 March 2022. There remains uncertainty as to whether this appeal was notified to the Tribunal out of time, and, if so, by how long. On one view, it was filed only a matter of days late. HMRC originally objected to the notification of this appeal, but that objection had fallen away by December 2022 (leading to the cancellation of a hearing which was to consider the point in January 2023). In the absence of objection, coupled with the likelihood that the period of delay is short, and insofar as not already (even if impliedly) dealt with, we consider that it is appropriate to extend time to notify the appeal, to the extent that any extension of time is required, to 15 March 2022. The appeal is therefore in time.