Vani Enterprises Limited v The Commissioners for HMRC
Decision date: 10 June 2026
Neutral citation: [2026] UKFTT 885 (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
Vani Enterprises appealed HMRC VAT and corporation tax assessments that arose from HMRC's s.73 VATA best-judgement VAT assessment (periods 02/16–11/17) and related para 41(1), sch 18 FA 1998 CT discovery assessments. The Tribunal found HMRC's VAT assessment was made to the best of their judgement using an appropriate methodology, and Vani failed to discharge the burden of proof with coherent, reconciled evidence to rebut the assessments. Both the VAT and CT appeals were dismissed and the taxpayer has 56 days to apply for permission to appeal.
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: high
An HMRC best-judgement assessment under s.73 VATA will be upheld where it is based on available material and a reasonable appropriate methodology, and the taxpayer fails, on the balance of probabilities, to provide coherent, reconciled evidence (invoices, spreadsheets and bank reconciliations) to rebut that assessment; a CT discovery assessment that relies on such a VAT assessment will likewise stand absent proof of errors or corroborating reconciliatory evidence.
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 commented that taxpayers seeking amendments after long delays are practically expected to provide reconciliations linking invoices, spreadsheet reports and bank payments, and that participation in ADR or post-ADR engagement does not remove the taxpayer's burden to produce dated, referenced and coherent documentation.