247 Jobline Limited v The Commissioners for HMRC

Decision date: 6 August 2026

Neutral citation: [2026] UKFTT 1146 (TC)

Overall AI summary confidence: high

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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

This case concerns applications to reinstate three struck-out VAT appeals and a permission request for a late appeal arising from HMRC’s 2021–22 investigation of related companies. The Tribunal found serious breaches of directions and lengthy unexplained delay, rejected the Second Appellant’s claim that he was impersonated by his brother, and refused all reinstatement and late-appeal applications. The Tribunal did not treat the substantive merits as determinative, finding them not so weak as to justify summary dismissal but also not weighing in favour of reinstatement.

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: medium

The Tribunal applied the three-stage test for reinstatement/late permission (length of delay, reasons for default, and balancing all circumstances) and refused relief where delay was long, explanations were inadequate, and the applicant failed to disclose relevant communications or call available witnesses; omission to disclose such material can justify adverse inferences and undermine claims of lack of awareness.

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 observed that an agent’s tone and prior communications can be probative about who authorised correspondence and whether a named director knew of proceedings, and that a director who does not ensure oversight may be held responsible for non-engagement. These comments were not treated as decisive to the outcome.

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