Shane de Silva v The Commissioners for HM Revenue and Customs [2021] UKUT 0275 (TCC)
Upper Tribunal Tax and Chancery decision of Judge Kevin Poole and Judge Ashley Greenbank on 11 November 2021
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Application for permission to notify late appeal to HMRC – whether FTT made error of law in refusing permission – whether FTT engaged properly with strength of Appellant’s case in carrying out its balancing exercise – held the FTT did make an error of law in failing to follow the guidance in Martland and in failing to give reasons which properly supported its decision, but the FTT’s decision was nonetheless a correct one in the light of the Martland criteria applied correctly – decision re-made on that basis.
Published 11 November 2021