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Legal analysis reveals imminent appeal expiration for tribunal token holders, highlighting a critical condonable window before tax appeals are permanently barred.
Most of the commentary written this summer told corporate taxpayers to file before 31 July 2026. That deadline has passed, and the commentary has moved on. It should not have. A large cohort of appellants did not file by 31 July — they generated a token, and their appeals are now sitting on a 60-day clock that nobody is watching.For tokens generated on the last day, that clock runs out around 29 September 2026. When it does, the appeal is not late. It is dead.This note sets out where limitation now stands, why the condonable window may be a month longer than the published commentary says, and what remains when the Tribunal's door has closed
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Manoj Thakur (2026) studied this question.
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