This was an appeal against an assessment raised by HM Revenue and Customs (HMRC) as a result of an error correction notice having been filed by the appellant. The assessment was issued to the appellant on 22 July 2023, for the periods 09/2019, 11/2019, 02/2020, 03/2020, 06/2020 and 03/2021. The only issue between the parties was whether that assessment was raised within the statutory time limits.â¯
On 15 July 2022, the appellant's agent filed an error correction notice with HMRC on behalf of the appellant, which was acknowledged electronically the same day. It seems that HMRC then lost or misfiled the error correction notice that they had received. On 22 May 2023, the appellant's agent emailed HMRC to provide a further copy of the error correction notice. This followed a telephone call from the agent to HMRC, to enquire about progress, in which the agent was told HMRC had no record of the error correction submitted. â¯
On 27 June
