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PART 11Reviews and appeals

CHAPTER 2Reviews

Review of appealable decisions

236Late notice of review

(1)This section applies in a case where—

(a)notice of review may be given to Revenue Scotland under this Part, but

(b)no notice is given before the relevant time limit.

(2)Notice may be given after the relevant time limit if—

(a)Revenue Scotland agrees, or

(b)where Revenue Scotland does not agree, the tribunal gives permission.

(3)Revenue Scotland must agree to notice being given after the relevant time limit if the appellant has requested that Revenue Scotland does so and Revenue Scotland is satisfied—

(a)that there was reasonable excuse for not giving the notice before the relevant time limit, and

(b)that the request has been made without unreasonable delay.

(4)If a request of the kind referred to in subsection (3) is made, Revenue Scotland must notify the appellant whether or not Revenue Scotland agrees to the request.

(5)In this section “relevant time limit”, in relation to notice of review, means the time before which the notice is to be given (but for this section).