SCHEDULE 36Information and inspection powers
Part 7Penalties
F1Procedure on appeal against ... penalty
48
(1)
Notice of an appeal under paragraph 47 must be given—
(a)
in writing,
(b)
before the end of the period of 30 days beginning with the date on which the notification under paragraph 46 was issued, and
(c)
to HMRC.
(2)
Notice of an appeal under paragraph 47 must state the grounds of appeal.
(3)
On an appeal under paragraph 47(a) F2that is notified to the tribunal, the tribunal may confirm or cancel the decision.
(4)
On an appeal under paragraph 47(b) F2that is notified to the tribunal, the tribunal may—
(a)
confirm the decision, or
(b)
substitute for the decision another decision that the officer of Revenue and Customs had power to make.
(5)
Subject to this paragraph and paragraph 49, the provisions of Part 5 of TMA 1970 relating to appeals have effect in relation to appeals under this Part of this Schedule as they have effect in relation to an appeal against an assessment to income tax.