[49EA Nature of review: penalties under Schedule 24 to FA 2021]

[49EA  Nature of review: penalties under Schedule 24 to FA 2021]

[(1)     This section applies if—

(a)     notice of appeal has been given to HMRC under paragraph 22(b) of Schedule 24 to the Finance Act 2021 in respect of a penalty, and

(b)     HMRC are required to review

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