216 Late appeal against final judicial ruling

Appeals out of time

216  Late appeal against final judicial ruling

(1)     This section applies where a final judicial ruling (“the original ruling”) is the subject of an appeal by reason of a court or tribunal granting leave to appeal out of time.

(2)     If a follower notice has been given identifying the original ruling under section 206(a), the notice is suspended until such time as HMRC notify P that—

(a)     the appeal has resulted in a judicial ruling which is a final ruling, or

(b)     the appeal has been abandoned

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