Upper Tribunal Tax and Chancery Chamber UT/2024/000087 - [2025] UKUT 00287 (TCC) Fecha: 04-Jul-2025 Conclusions Conclusion28.Permission to appeal is GRANTED in respect of Ground 1 only. Permission to appeal is REFUSED on Grounds 3 and 4.JUDGE PHYLLIS RAMSHAWRelease date: 20 August 2025 Heading Introduction Jurisdiction of the Upper Tribunal The Appellant’s grounds of appeal against the FTT Decision Ground 1 – s455 Corporation Tax Act 2010 (‘ CTA 2010 ’) Discussion Ground 3 – failure to apply the correct time limit Discussion Ground 4 – Procedural unfairness Discussion Conclusions