![TC09594 - [2025] UKFTT 00893 (TC)](https://backend.juristeca.com/files/emisores/logo_7HSuEAV.png){kind=logo}
HMRC must, within the relevant period, notify the appellant of HMRC's view of the matter in question HMRC must review the matter in question in accordance with section 49E
HMRC must, within the relevant period, notify the appellant of HMRC's view of the matter in question.
HMRC must review the matter in question in accordance with section 49E.
The appellant may not notify HMRC that the appellant requires HMRC to review the matter in question and HMRC shall not be required to conduct a review if—
the appellant has already given a notification under this section in relation to the matter in question,
HMRC have given a notification under section 49C in relation to the matter in question, or
the appellant has notified the appeal to the tribunal under section 49D.
In this section “relevant period” means—
the period of 30 days beginning with the day on which HMRC receive the notification from the appellant, or
such longer period as is reasonable.
- Heading
- INTRODUCTION
- THE LAW
- THE EVIDENCE AND THE FACTS
- DISCUSSION
- Submissions - not late
- My view - not late
- Late appeal
- He accepted that the delay in notifying the appeal to the tribunal is serious and significant
- Mr Finerty thought that he had made a valid request for a statutory review in the Valentine’s Day letter Secondly, the appellant reasonably relied on BP. He was under the mistaken impression that Mr Finerty had responded to HMRC’s letter of 8 March 2
- The merits of the parties respective positions did not militate strongly one way or the other
- The appellant’s delay is at worst 586 days and best 62 days. These are both serious and significant
- The merits of the appellant’s underlying case are weak My view
- DECISION
- RIGHT TO APPLY FOR PERMISSION TO APPEAL
- An appeal may be brought against–
- In relation to an appeal under section 31(1) (a) or (c) of this Act –
- In relation to an appeal under section 31(1) (b) of this Act –
- (4A) In relation to an appeal under section 31(1)(d) against a simple assessment—
- HMRC must, within the relevant period, notify the appellant of HMRC's view of the matter in question HMRC must review the matter in question in accordance with section 49E
- 49C— HMRC offer review Subsections (2) to (6) apply if HMRC notify the appellant of an offer to review the matter in question
- Subsections (2) and (3) do not apply in a case where—
- The nature and extent of the review are to be such as appear appropriate to HMRC in the circumstances
- The review may conclude that HMRC's view of the matter in question is to be—
- Conclusions