Article 7 Reply to notice of appeal
(1)
Within the period specified in paragraph (2) below, the Commissioner may send to the appellant and the Tribunal a notice in reply, containing the Commissioner’s reasons for opposing the appeal.
(2)
The notice in reply may be sent at any time within 28 days from—
(a)
where the appeal is out of time, the Tribunal’s decision to permit the appellant to appeal out of time;
(b)
otherwise, the sending to the Commissioner of the copy of the notice of appeal.