Visu Tech Limited v The Commissioners for HMRC

Decision date: 6 August 2026

Neutral citation: [2026] UKFTT 1136 (TC)

Overall AI summary confidence: high

AI Notice: Any short overview, ratio decidendi summary or obiter dicta summary shown on this page is AI-generated, provided only to help users assess potential relevance more quickly, and may be wholly inaccurate. No liability is accepted for the accuracy of any such summary, regardless of any AI confidence rating shown. Users should check the underlying decision and obtain appropriate legal advice rather than relying on any summary.

Short overview

This short overview is intended to summarise the case, issues and outcome so far as they are supported by the judgment.

AI confidence in this short overview: high

Visu Tech Ltd sought permission to bring a 702‑day late appeal against three HMRC assessments dated 24 February 2023 totalling £36,035.84 relating to alleged overclaimed CJRS payments. The First-tier Tribunal applied the three-stage Martland approach, found the delay significant, rejected the appellant’s inconsistent and unsupported explanations, and concluded there was no good reason to grant permission. The application for permission to bring a late appeal was dismissed.

Ratio decidendi

This summary is intended to identify the ratio decidendi, meaning the legal reasons for deciding and the binding part of the decision.

AI confidence in this ratio decidendi summary: high

The Tribunal applied the Martland three-stage test for late‑appeal permission: (i) assess length of delay, (ii) assess reasons for the delay, and (iii) balance all relevant circumstances (including prejudice and importance of timeliness). Where the delay is long and explanations are conflicting or unsupported by evidence, that will not establish a good reason to grant permission.

Obiter dicta

This summary is intended to identify obiter dicta, meaning observations made by the way that were not necessary to deciding the case and are not binding.

AI confidence in this obiter dicta summary: medium

The judgment noted, as non‑decisive observations, that loss of the right to challenge an assessment is a common consequence of refusing late permission and that absence of witness statements or documentary evidence to support a late‑appeal explanation undermines the appellant’s case.