Late notice of appeal
37(1)This paragraph applies in a case where—
(a)notice of appeal may be given to HMRC under this Schedule, but
(b)no notice is given before the relevant time limit.
(2)Notice may be given after the relevant time limit if—
(a)HMRC agree, or
(b)where HMRC do not agree, the tribunal gives permission.
(3)HMRC must agree to notice being given after the relevant time limit if the appellant has requested in writing that HMRC do so and HMRC are 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 mentioned in sub-paragraph (3) is made, HMRC must notify the appellant whether or not HMRC agree to the request.
(5)In this paragraph “relevant time limit”, in relation to notice of appeal, means the time before which the notice must to be given (disregarding this paragraph).