Onebill Residential Ltd v Commissioners for Her Majesty's Revenue and Customs
Decision date: 28 June 2010
Neutral citation: [2010] UKFTT 290 (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
Onebill Residential Ltd appealed HMRC decisions disallowing input tax (an amendment to 09/07 return for £12,848.38) and a best‑judgment assessment for periods 12/05–06/07 (£106,453). The tribunal heard unchallenged evidence that Onebill failed to produce original invoices, payment evidence or complete accounting records despite directions, and that supplier checks suggested invoices were unpaid. The tribunal dismissed both appeals, upholding the disallowance and the best‑judgment assessment.
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
From the tribunal’s findings, a claimant seeking input tax must produce valid original invoices and supporting accounting records so entitlement can be verified; where the taxable person fails to produce required records, HMRC may make a best‑judgment assessment under the relevant statutory power disallowing input tax.
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 supplier evidence indicating invoices were unpaid and treated as bad debts undermined the appellant’s claims and justified the need for cross‑checking; it also observed that non‑compliance with tribunal directions (including an unless order) supports adverse factual findings against a party who fails to produce documents.