Nick Davies comments on the recent case of Rohit Kotecha v HMRC, in which an application to reinstate an appeal was successful despite the application being made late.
We were delighted to obtain Tribunal’s decision in this recent case, heard in February, in which we were seeking the reinstatement of an appeal that had been struck out. Actually, we were doubly up against it because, as well as the strike out of the appeal, the application to reinstate it had been made 56 days late.
Thankfully, Judge Popplewell was able to find in favour of the taxpayer on both elements of the case, but the very fact that it had to be heard at Tribunal in the first place offers some salutary lessons for all tax practitioners which will be covered later in this article.
Download the full article below: