Ramachandren Narayanasamy v HMRC
Decision date: 8 January 2025
Neutral citation: [2025] UKFTT 21 (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
The appellant sought costs under FTT Rule 10 after HMRC withdrew from an appeal about a 2013 closure notice concerning goodwill and lease valuations. The Tribunal found HMRC had reasonably believed goodwill had been agreed at £165,000 and only withdrew after the appellant's October 2022 witness statement revealed a broader challenge, so HMRC's conduct was not improper or unreasonable. The application for costs was dismissed and no quantum was assessed.
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
Where a respondent reasonably defends an appeal based on a held understanding of agreed facts (here, a goodwill valuation) and only withdraws after new pleaded material exposes a wider dispute, that withdrawal does not automatically justify an order for costs; entitlement to costs turns on conduct in the appeal proceedings and whether that conduct was unreasonable in light of the material before the respondent at the time.
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 indicated caution in shifting costs in the Tax Chamber because cost-shifting is the exception outside the complex track. It also expressed concern about SAV’s earlier valuation error not being explained or apologised for, but noted that such concern did not render HMRC’s conduct unreasonable for costs purposes.