Blindspot Global Limited v The Commissioners for HMRC

Blindspot Global Limited v The Commissioners for HMRC

The Appellant's application for costs was made approximately 17 months late, which is a serious and significant delay. The Appellant failed to provide a good reason for the delay, as evidence showed Mr Moran was able to instruct agents and pursue complaints during the relevant period. There was no explanation of how HMRC acted unreasonably in the conduct of the Tribunal proceedings. The prejudice to HMRC in reopening concluded proceedings outweighed any limited prejudice to the Appellant. The Tribunal refused to grant an extension of time, and the costs application was not admitted.

Parties
Appellant: Blindspot Global Limited; Respondents: The Commissioners for His Majesty’s Revenue and Customs
Jurisdiction
England and Wales
Judgment Date
23 May 2025
Procedural Posture
Tax Tribunal Appeal / Costs Application After Withdrawal of Appeal
Outcome
Application for extension of time to apply for costs refused; costs application unsuccessful.
Legal Topics
Value Added Tax, Costs Applications, Extension of Time, Unreasonable Conduct

Case Brief

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Parties

Blindspot Global Limited

Appellant

The Commissioners for His Majesty’s Revenue and Customs

Respondents

Procedural Posture

Tax Tribunal Appeal / Costs Application After Withdrawal of Appeal

  1. 1 Whether the Appellant should be granted an extension of time to make a costs application
  2. 2 Whether HMRC acted unreasonably in the conduct of the proceedings

Ratio Decidendi

The Appellant's application for costs was made approximately 17 months late, which is a serious and significant delay. The Appellant failed to provide a good reason for the delay, as evidence showed Mr Moran was able to instruct agents and pursue complaints during the relevant period. There was no explanation of how HMRC acted unreasonably in the conduct of the Tribunal proceedings. The prejudice to HMRC in reopening concluded proceedings outweighed any limited prejudice to the Appellant. The Tribunal refused to grant an extension of time, and the costs application was not admitted.

Court Disposition

Application for extension of time to apply for costs refused; costs application unsuccessful.