Adrian Atkins v The Commissioners for HMRC

Adrian Atkins v The Commissioners for HMRC

The delay in bringing the appeal was both serious and significant, and no good reason was provided for the lateness. The prejudice to the appellant did not outweigh the importance of respecting statutory time limits. The application for a late appeal was therefore refused.

Parties
Appellant: Adrian Atkins; Respondents: The Commissioners for His Majesty’s Revenue and Customs
Jurisdiction
England and Wales
Judgment Date
22 July 2025
Procedural Posture
Tax Appeal / Application for Permission to Appeal Out of Time (late Appeal)
Outcome
Application for permission to make a late appeal dismissed
Legal Topics
VAT Credit Denial, Late Appeal, Tribunal Procedure, Review Decision Timing
Tax Law VAT Credit Denial Late Appeal Tribunal Procedure Review Decision Timing

Case Brief

Summary, issues, holding and outcome

More case intelligence is available

Unlock the full research layer for this judgment.

Full judgment text Downloadable case file Legal principles 3 Authorities cited 6 Party arguments 2 Amounts and remedies 3
Sign in to unlock

Parties

Adrian Atkins

Appellant

The Commissioners for His Majesty’s Revenue and Customs

Respondents

Procedural Posture

Tax Appeal / Application for Permission to Appeal Out of Time (late Appeal)

Legal Issues

  1. 1 Whether the appellant should be granted permission to appeal out of time against HMRC's decision to deny a VAT credit
  2. 2 Whether the delay in bringing the appeal was serious or significant and if there was good reason for the delay
  3. 3 Whether the review decision was notified late and its effect on the appeal

Ratio Decidendi

The delay in bringing the appeal was both serious and significant, and no good reason was provided for the lateness. The prejudice to the appellant did not outweigh the importance of respecting statutory time limits. The application for a late appeal was therefore refused.

Court Disposition

Application for permission to make a late appeal dismissed