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(1)The relevant person may apply to the tribunal for a direction that a closure notice is to be given within a specified period.
(2)The tribunal hearing the application must give a direction unless satisfied that Revenue Scotland has reasonable grounds for not giving a closure notice within that period.
(3)In this paragraph “the tribunal” means—
(a)the First-tier Tribunal, or
(b)where determined by or under tribunal rules, the Upper Tribunal.