The list of appealable matters in ¶62-200 is exhaustive. Any matter, with respect to which no statute expressly provides that an appeal lies to the tribunal, is non-appealable although possibly judicial review may be available.

A distinction must be drawn between those matters which are appealable, but where there is either an inherent or a statutory restriction on the scope of the tribunal’s jurisdiction to interfere with a decision by HMRC (¶62-206 and ¶62-207) on the one hand, and those matters where no appeal lies at all on the other. This paragraph in the commentary concerns the latter.

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