Shafique Uddin was the sole director and shareholder of Kazitula Limited, which ran a restaurant business.

In 2017, HMRC issued a series of VAT and corporation tax assessments and deliberate inaccuracy penalties totalling £532,266.90 based on its view that sales had been suppressed over many years.

Shortly afterwards Kazitula went into creditors’ voluntary liquidation. HMRC sent Uddin personal liability notices (PLNs) for the unpaid tax totalling £212,506.35.

Uddin, and the liquidators of the company, lodged their respective appeals with the tribunal between 16 and 18 months outside of the 30-day time limit.