Application for retrospective extension of time limit denied

The taxpayer had appealed to the First-tier Tribunal in June 2016 but HMRC asked for a direction to extend the time in which it was to deliver its statement of case by 60 days after the release of decisions in other similar appeals. The tribunal dismissed those appeals in July 2018 but in light of further similar appeals to be heard HMRC said it intended to ask for another extension. However due to various administrative errors and a change in HMRC litigator no such application was made. Further delay was caused by HMRC awaiting the outcome of further appeals which transpired not to be relevant to the taxpayer’s case.

Eventually in December 2021 HMRC applied to for a time extension to serve its statement of case. The taxpayer appealed.

On HMRC’s delay in applying for an extension of time the First-tier Tribunal referred to...