Parvaiz Akhtar v The Commissioners for HMRC
Decision date: 19 September 2025
Neutral citation: [2025] UKFTT 1122 (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 HMRC best‑judgement VAT assessments totalling £29,199.19 for periods 12/19–03/23 against Mr Akhtar, who operated an off‑licence and had incomplete till/journal records. The Tribunal found HMRC acted "to the best of their judgment" using available till z‑readings and representative periods and that Mr Akhtar failed to discharge the burden of proof to show the assessed quantum was incorrect. The assessments were therefore upheld in full.
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
Where a taxpayer fails to keep required records and does not provide material requested, HMRC may rely on available till data and reasonably representative periods to make best‑judgement assessments; such assessments will not be set aside unless they are dishonest, capricious, wholly unreasonable or a spurious guess, and an officer may consult others while still making a valid best‑judgement decision.
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 suggested that evidence first raised only at hearing (for example, new details about who worked Sundays) may be treated as evidence on quantum rather than material that HMRC should have considered when making the assessment. It also indicated comparative or expert evidence not directed by the Tribunal may be excluded from consideration.