247 Jobline Limited v The Commissioners for HMRC

Facts

HMRC investigated three related companies in 2021 and 2022. The Second Appellant, Mr Maaz Mohiuddin, was sole director of two of them, including the First Appellant, 247 Jobline Limited; another of his brothers was sole director of the third. During the investigation HMRC dealt with a person who held himself out to be the Second Appellant. HMRC concluded there had been a loss of tax, de-registered the companies from VAT, raised assessments, issued a penalty to each company under Section 69C VATA 1994 and issued a Personal Liability Notice to the Second Appellant in respect of each penalty under Section 69D VATA 1994. Six appeals were filed in 2022. Directions were not complied with; two appeals of The Jobline Limited were struck out on 14 February 2024 and the remaining four, including the three now in issue, were struck out automatically on 23 April 2024 for breach of an Unless order, confirmed to the parties on 10 May 2024. No reinstatement application was made within the 28 days allowed. After HMRC's publication team wrote to the Second Appellant in January 2025, he applied on 5 March 2025 (amended 10 March 2025) to reinstate three appeals, saying he had been impersonated throughout by his brother MU, and on 14 March 2025 applied for permission to appeal the third PLN out of time.