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
Summary, issues, holding and outcome
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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
Legal Issues
- 1 Whether the Appellant should be granted an extension of time to make a costs application
- 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.
Full Case Text
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