Raza Miah v The Commissioners for HMRC
Decision date: 3 September 2026
Neutral citation: [2026] UKFTT 1278 (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
This appeal concerned HMRC discovery assessments for tax years 2005/06–2013/14 and related penalties, based largely on large unexplained bank lodgements which the appellant failed to substantiate. The First-tier Tribunal held the assessments were competently made, within the extended 20-year time limit because the appellant’s conduct was deliberate, and that HMRC’s inferences and best‑judgement figures were fair; the varied assessments totalling £415,942.10 and penalties totalling £214,980.18 were upheld and the appeal dismissed.
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 taxpayer, after being required to do so, fails to provide material information, HMRC may make reasonable inferences from available material and raise discovery assessments on that basis; officers are not obliged to undertake exhaustive further investigations before assessing. A settlement recorded later (here, a Tomlin Order) does not retrospectively alter who received taxable income in the years under appeal, and competent, timely discovery assessments stand unless the taxpayer rebuts them.
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 that admitting late documents can be appropriate to ensure the Tribunal and parties have relevant material, but late witness statements that materially change a party’s case may be refused; and that representative submissions are not evidence and carry no evidential weight.