Mohammed Akrami v The Commissioners for HMRC

Mohammed Akrami v The Commissioners for HMRC

The Tribunal refused permission to admit the late appeals because the delays were serious and significant, there was no good reason for the delays, the appellant was professionally advised throughout, and the appeals had little merit. Finality and compliance with statutory time limits outweighed any prejudice to the appellant.

Parties
Appellant: Mohammed Akrami; Respondents: The Commissioners for His Majesty’s Revenue and Customs
Jurisdiction
England and Wales
Judgment Date
11 September 2024
Procedural Posture
Tax Appeal / Application for Permission to Notify Late Appeals
Outcome
Applications for permission to notify late appeals refused; appeals not admitted.
Legal Topics
Late Appeals, Penalties, Personal Liability Notices, Jurisdiction, Procedural Compliance
Tax Law Civil Procedure Late Appeals Penalties Personal Liability Notices Jurisdiction Procedural Compliance

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Parties

Mohammed Akrami

Appellant

The Commissioners for His Majesty’s Revenue and Customs

Respondents

Procedural Posture

Tax Appeal / Application for Permission to Notify Late Appeals

Legal Issues

  1. 1 Whether the Tribunal should grant permission to admit late appeals in three tax penalty cases
  2. 2 Whether there was a good reason for the delay in filing the appeals
  3. 3 Whether the appeals have reasonable prospects of success

Ratio Decidendi

The Tribunal refused permission to admit the late appeals because the delays were serious and significant, there was no good reason for the delays, the appellant was professionally advised throughout, and the appeals had little merit. Finality and compliance with statutory time limits outweighed any prejudice to the appellant.

Court Disposition

Applications for permission to notify late appeals refused; appeals not admitted.