Mochars Ltd v The Commissioners for HMRC
Decision date: 20 February 2026
Neutral citation: [2026] UKFTT 313 (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
Mochars Ltd appealed HMRC's reduction of its VAT repayment claim for period 12/23, challenging HMRC's refusal to allow input tax on 24 transactions (total £6,128.78) for which no invoices or corroborative evidence were produced. The Tribunal found HMRC had repeatedly requested evidence, considered and lawfully exercised the discretion in regulation 29(2), and reasonably refused the 24 claims; the appeal was dismissed and HMRC's reduction to £76.00 upheld.
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 held that regulation 29(2)'s proviso does not impose an obligation on HMRC to inform taxpayers what alternative evidence might be acceptable; instead HMRC may determine in which cases alternative evidence is to be accepted, and an officer need not cite the statutory source by name so long as relevant considerations are taken into account and irrelevant ones excluded.
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 (obiter) that a pre-decision letter need not name the statutory provision for a discretion to be valid, and that repeated failure over a prolonged period to provide bank/credit-card statements and an audit trail can justify refusal of input tax claims for lack of corroboration.
Warning
This chunk contains substantial repetition of the same text and factual recital. Notes contain substantial repetition and focus on a single chunk of the judgment; they may be noisy though not necessarily materially incomplete.