In Conservatory Insulations Northwest Ltd v HMRC [2025] UKFTT 705 (TCC) (12 June) the FTT refused HMRC’s application to strike out the appeal and allowed the taxpayer’s appeal. The FTT agreed with the taxpayer that an assessment had not been made on time.
HMRC provided two reasons for applying to strike out the appeal: (i) the FTT had no jurisdiction to consider the issue; and (ii) the appeal had no reasonable prospect of success. These were based on HMRC’s argument that the assessment was made when it had been prepared by an HMRC officer not on the later date when it was counter-signed by a more senior HMRC officer (which in this case was more than one year after HMRC had in its possession the information which justified the making of the assessment).
However the FTT held that...
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In Conservatory Insulations Northwest Ltd v HMRC [2025] UKFTT 705 (TCC) (12 June) the FTT refused HMRC’s application to strike out the appeal and allowed the taxpayer’s appeal. The FTT agreed with the taxpayer that an assessment had not been made on time.
HMRC provided two reasons for applying to strike out the appeal: (i) the FTT had no jurisdiction to consider the issue; and (ii) the appeal had no reasonable prospect of success. These were based on HMRC’s argument that the assessment was made when it had been prepared by an HMRC officer not on the later date when it was counter-signed by a more senior HMRC officer (which in this case was more than one year after HMRC had in its possession the information which justified the making of the assessment).
However the FTT held that...
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