After the case has been put for HMRC the next stage of the
proceedings is normally the final reply for the appellant. This
will deal particularly with any fresh points made by you in your
statement of the case for HMRC, and generally seek to undo the
effect of that statement on the Commissioners.
Where, exceptionally, new contentions or arguments are
introduced into this reply, you should at once claim the right of
further reply, and should deal with such contentions or arguments
at the conclusion of the appellant's final reply. Apart from this,
you have no right of further reply.
