Complete Electrical Services (NW) Limited v The Commissioners for HMRC
Decision date: 16 January 2026
Neutral citation: [2026] UKFTT 128 (TC)
Overall AI summary confidence: medium
Short overview
This short overview is intended to summarise the case, issues and outcome so far as they are supported by the judgment.
AI confidence in this short overview: medium
This appeal concerned a best-judgment VAT assessment issued by HMRC (amended to £46,791) for periods 10/15–01/19 after a compliance visit; the taxpayer, Complete Electrical Services (NW) Ltd (CESNW), challenged the assessment and sought to admit substantial late documentary material. The Tribunal found HMRC's assessment was made to the best of their judgment using an appropriate methodology (representative sampling/extrapolation and arithmetically sound calculations) based on available material, excluded the late evidence, and dismissed the appeal. CESNW was given 56 days to apply for permission to appeal under Rule 39.
Ratio decidendi
This summary is intended to identify the ratio decidendi, meaning the legal reasons for deciding and the binding part of the decision.
AI confidence in this ratio decidendi summary: medium
From the judgment as recorded, the Tribunal upheld that HMRC may make a best-judgment VAT assessment under section 73 VATA 1994 where returns or evidence are incomplete, provided there is some material to support a reasonable, non-arbitrary decision; a representative sampling/extrapolation combined with correct arithmetic can constitute an appropriate basis for such an assessment. The Tribunal also applied procedural principles permitting refusal to admit substantial late evidence not in the hearing bundle or provided to other parties.
Obiter dicta
This summary is intended to identify obiter dicta, meaning observations made by the way that were not necessary to deciding the case and are not binding.
AI confidence in this obiter dicta summary: medium
The notes indicate obiter observations that repeated postponements by a party weigh against further delay and that the Tribunal may proceed where parties have had notice and opportunity to participate. The Tribunal also commented that technical difficulties experienced by a representative who then failed to rejoin do not automatically justify admitting new evidence after the hearing.
Warning
The chunk contains substantial repetition of material (duplication of paragraphs), which may be distracting but does not appear to change the substance. Notes contain duplicated material and may be somewhat noisy; they nevertheless appear to capture the principal findings but could be materially incomplete.