TAJINDER PAWAR v THE COMMISSIONERS FOR HIS MAJESTY’S REVENUE AND CUSTOMS [2025] UKUT 00309 (TCC)
Upper Tribunal Tax and Chancery decision of JUDGE SWAMI RAGHAVAN and JUDGE NICHOLAS PAINES KC on 17 September 2025
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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
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Published 18 September 2025