Smaira Ghani v The Commissioners for HMRC

Decision date: 8 October 2026

Neutral citation: [2026] UKFTT 1410 (TC)

Overall AI summary confidence: high

AI Notice: Any short overview, ratio decidendi summary or obiter dicta summary shown on this page is AI-generated, provided only to help users assess potential relevance more quickly, and may be wholly inaccurate. No liability is accepted for the accuracy of any such summary, regardless of any AI confidence rating shown. Users should check the underlying decision and obtain appropriate legal advice rather than relying on any summary.

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 concerns HMRC's application to strike out Mrs Ghani's 16 June 2025 Tribunal Notice of Appeal for want of jurisdiction. The Tribunal held the attached 14 April 2025 Statement of Liabilities was not an HMRC decision and therefore not appealable, so the Notice did not identify an appealable decision and the appeal was struck out. HMRC later issued a 4 November 2025 decision refusing Mrs Ghani's appeal against a late‑payment penalty, which may in principle be the subject of a separate (timely or permissioned late) 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

The Tribunal's binding reasoning is that it lacks jurisdiction where a Notice of Appeal does not identify an appealable HMRC decision or include the written record/details required by Rule 20; a Statement of Account/Statement of Liabilities that is not a decision does not found an appeal to the Tribunal.

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 decision records, as non‑binding observations, that statutory interest on unpaid tax is not itself appealable, and that if HMRC subsequently issues a proper appealable decision (such as the 4 November 2025 refusal of the penalty) that decision could, in principle, be appealed to the Tribunal subject to time limits and permission where necessary.

Warning

- The chunk contains repeated passages and some duplication of material. Notes contain some repeated passages and duplication. None

Source links

Judgment page Judgment PDF Judgment XML