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 address for appeal by September 2022 but failed to act. No good reason was provided for the delay, and the balance of prejudice, finality, and statutory compliance weighed against granting permission....

Source-derived case information.

Citation
[2026] UKFTT 249
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 Instance 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 Instance Decision

Legal Issues

  1. 1 Whether permission should be granted for a late appeal against a company officer liability 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 address for appeal by September 2022 but failed to act. No good reason was provided for the delay, and the balance of prejudice, finality, and statutory compliance weighed against granting permission. The application for a late appeal was refused.

Court Disposition

Application for permission to make a late appeal refused.

Orders

  • Permission to make a late appeal is refused.