UT/2024/000022 - [2025] UKUT 00309 (TCC)

Case Number: UT/2024/000022

Rolls Building, London

PROCEDURE – application for permission to make a late appeal in relation to Personal Liability Notice – stage three of approach suggested in Martland v HMRC - whether FTT erred in failing to take account of various relevant factors and to properly identify relevant principles regarding attribution of adviser’s failure to those of litigant - no – whether FTT erred in according particular weight to the importance of time limits – yes – decision set aside and remade - appeal dismissed

Written submissions: 13 and 19 August 2025

Judgment date: 17 September 2025

Before

JUDGE SWAMI RAGHAVAN

JUDGE NICHOLAS PAINES KC

Between

TAJINDER PAWAR

Appellant

and

THE COMMISSIONERS FOR HIS MAJESTY’S REVENUE AND CUSTOMS

Respondents

Representation:

For the Appellant: David Bedenham KC and Christopher McNall, Counsel, instructed by SP Legal Solutions

For the Respondents: Jenny Goldring, Counsel, instructed by the General Counsel and Solicitor to His Majesty’s Revenue and Customs

DECISION