Section 84(4A)

Where an appeal is brought against the refusal of an application such as is mentioned in section 43B(1) or (2) on the grounds stated in section 43B(5)(c)— the tribunal shall not allow the appeal unless it considers that HMRC could not reasonably have been satisfied that there were grounds for refusing the application, the refusal shall have effect pending the determination of the appeal, and if the appeal is allowed, the refusal shall be deemed not to have occurred.

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Source: legislation.gov.uk · retrieved 2026-07-28