[2026] UKUT 00206 (TCC) Bharat Patel v HMRC
Upper Tribunal Tax and Chancery decision of Judge Raghavan and Judge Poole on 1 June 2026
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PROCEDURE –– application for permission to notify late appeals against VAT assessments – whether the FTT erred in its stage 3 evaluation under Martland by failing to treat a section 73(6) VATA time-limit point as an obviously very strong merits factor – whether the FTT erred in its assessment of prejudice by treating the dispute as “closed” in light of Lord Advocate v Shanks (challenge to validity of VAT assessments possible in collection proceedings despite no appeal before FTT) – no – appeal dismissed
Updates to this page
Published 1 June 2026