Rahim Dhanani v The Commissioners for HMRC

Decision date: 18 September 2026

Neutral citation: [2026] UKFTT 1358 (TC)

Overall AI summary confidence: high

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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 case management decision concerned whether HMRC could, late in the proceedings, amend its Statement of Case and adduce expert valuation evidence in response to the Appellant’s DCF report. The Tribunal refused HMRC’s application to amend, granted the Appellant permission to rely on its factual and expert evidence, and dismissed HMRC’s expert-evidence application as no longer pursued. The appeal therefore proceeds on the original pleadings with the Appellant’s expert report admitted.

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 late application to amend pleadings requires a full explanation and strong justification; the Tribunal must weigh the nature and extent of the proposed amendment, the delay and resulting prejudice, and the overriding objective. Where the core issues (here, concern about goodwill/intangibles and valuation methodology) were already evident from earlier pleadings and correspondence, a belated amendment prompted solely by receipt of an expert report can be unjustified and should be refused.

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 noted that an expert report adopting a new valuation methodology does not necessarily create a new issue when the underlying complaint was previously pleaded and apparent from correspondence. It also observed that reliance on a later transaction’s valuation may have limited probative value as evidence that a party accepted a methodology for an earlier valuation date.