Najat Hamasala v The Commissioners for HMRC
| Court | Upper Tribunal (Tax and Chancery Chamber) |
| Judgment Date | 02 July 2026 |
| Neutral Citation | [2026] UKUT 246 (TCC) |
| Date | 02 July 2026 |
| Year | 2026 |
1
UPPER TRIBUNAL
TAX AND CHANCERY CHAMBER
Neutral Citation Number: [2026] UKUT 00246 (TCC)
Applicant: Najat Hamasala Tribunal Ref: UT-2026-000028
Respondents: The Commissioners for His Majesty’s Revenue and Customs
APPLICATION FOR PERMISSION TO APPEAL
DECISION NOTICE FOLLOWING HEARING ON 16 JUNE 2026
JUDGE JEANETTE ZAMAN
1. The applicant, Najat Hamasala, applied to the Upper Tribunal (Tax and Chancery
Chamber) for permission to appeal against the decision (the “FTT Decision”) of the First-tier
Tribunal (Tax Chamber) (“FTT”) released on 23 October 2025 (TC/2024/04190).
2. The FTT Decision related to an application by Mr Hamasala for permission to make late
appeals to the FTT against a closure notice and discovery assessments, and for permission to
notify his appeals against late filing penalties to HMRC out of time. I refer to these together as
“the late appeals”. The FTT refused permission for Mr Hamasala to make the late appeals.
References below in the form FTT[x] are to paragraphs of the FTT Decision.
3. The FTT refused permission to appeal against the FTT Decision in a decision released
on 30 January 2026 (the “FTT PTA Refusal”). On 10 February 2026 Mr Hamasala applied to
the Upper Tribunal for permission to appeal (the “Application”) and I refused to grant
permission on the papers (the “UT Papers Refusal”). Mr Hamasala applied for that decision to
be re-considered at a hearing. The hearing was held at the Rolls Building on 16 June 2026 and
was attended by Mr Hamasala. HMRC had been notified of the hearing and did not attend.
4. As explained below, I have REFUSED permission to appeal.
RELEVANT LAW ON GRANTING PERMISSION
5. Pursuant to s11(1) Tribunals Courts and Enforcement Act 2007 an appeal to the Upper
Tribunal may only be made on a point of law.
6. An application for permission to appeal must demonstrate that it is arguable that the FTT
made an error of law in reaching its decision which was material to that decision. “Arguable”
means an argument that carries a realistic as opposed to fanciful prospect of success.
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