SolvedHSTM05300 | Appeals and reviews: mandatory review
From HM Revenue & Customs · Help to Save Technical Manual
The notice of an appeal must be treated as a requirement by the appellant under section 49A(2)(a) of the Taxes Management Act 1970 for HMRC to review the matter in question. The process for requesting a review detailed at ARTG2010 should be followed.
The review process must be followed before the appellant has recourse to appeal to Tribunal.