Restoration decisions: Arranging for a review: Requiring HMRC to carry out a review
If the customer does not agree with HMRC’s restoration decision they may ask for a review within 45 days of the date of the decision letter.
If the customer asks for a review within the time limit HMRC must carry out a review of the restoration decision.
The customer must have asked for a review and either the review must be completed or the review period must have expired before any appeal against the decision can be made to the tribunal.
But see ARTG6040 where the customer provides new information and has not asked for a review.