L W Joinery and Flooring Ltd v The Commissioners for HMRC
Decision date: 28 August 2026
Neutral citation: [2026] UKFTT 1436 (TC)
Overall AI summary confidence: high
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: high
This appeal concerned CJRS assessments for employee Lance Williams and whether his reference salary was £2,996 or £512 per month. The Company sought permission after the substantive hearing to file a supplementary note to clarify HMRC RTI records; the Tribunal refused that application under its case‑management power, concluding it had already understood the records, that the note would not address the principal evidential deficiencies, and that the Company had not discharged the burden of proof for the higher salary. The decision therefore denied the post‑hearing filing and left the substantive appeal outcome determined on the existing evidence.
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
A tribunal may refuse permission to file further submissions after a substantive hearing where it is satisfied it already understands the disputed material and further submissions would not materially assist resolution; absent identification of new contemporaneous evidence addressing an evidential gap, additional technical submissions about electronic records are unlikely to change the outcome.
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 Tribunal treated the matter as a case‑management exercise under rule 5 rather than as governed by the Upper Tribunal decision cited by the Company (William Martland) and expressed concern that allowing the supplementary note would provoke unnecessary additional rounds of submissions on issues already explored at the hearing.