Ram v Revenue and Customs (Procedure - Application for permission to make a late appeal) [2026] UKFTT 249 (TC) (12 February 2026)

Ram v Revenue and Customs (Procedure - Application for permission to make a late appeal) [2026] UKFTT 249 (TC) (12 February 2026)

The delay of approximately 867 days was serious and significant. The Appellant was aware of the correct process and time limits by early September 2022 but failed to act without good reason. No sufficient justification for the delay was provided. The balance of prejudice, the importance of finality, and statutory compliance outweighed any prejudice to the Appellant. Permission for a late appeal was refused.

Citation
[2026] UKFTT 249 (TC)
Parties
Appellant: Delve Ram; Respondents: The Commissioners for Her Majesty's Revenue and Customs
Jurisdiction
United Kingdom
Judgment Date
12 February 2026
Procedural Posture
Tax Appeal – Application for Permission to Make a Late Appeal / Application for Permission to Appeal Out of Time – First Tier Tribunal Decision
Outcome
Application for permission to make a late appeal refused.
Legal Topics
Late Appeal, Tribunal Procedure, VAT Penalties, Company Officer Liability, Statutory Time Limits
Tax Law Administrative Law Late Appeal Tribunal Procedure VAT Penalties Company Officer Liability Statutory Time Limits

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Parties

Delve Ram

Appellant

The Commissioners for Her Majesty's Revenue and Customs

Respondents

Procedural Posture

Tax Appeal – Application for Permission to Make a Late Appeal / Application for Permission to Appeal Out of Time – First Tier Tribunal Decision

Legal Issues

  1. 1 Whether permission should be granted for a late appeal against a company officer liability decision notice under section 69C VATA 1994
  2. 2 Whether the reasons for delay in appealing are sufficient to justify granting permission out of time

Ratio Decidendi

The delay of approximately 867 days was serious and significant. The Appellant was aware of the correct process and time limits by early September 2022 but failed to act without good reason. No sufficient justification for the delay was provided. The balance of prejudice, the importance of finality, and statutory compliance outweighed any prejudice to the Appellant. Permission for a late appeal was refused.

Court Disposition

Application for permission to make a late appeal refused.