iHeat.me Ltd v The Commissioners for HMRC
Decision date: 23 July 2026
Neutral citation: [2026] UKFTT 1089 (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
iHeat.me Ltd appealed a closure notice and brought multiple procedural applications alleging HMRC had behaved unreasonably (seeking costs, strike‑out/barring, summary determination and disclosure limitations) after settlement discussions. The Tribunal found HMRC's conduct, including late service of the statement of case and documents, was capable of reasonable explanation in context (including without‑prejudice settlement steps), refused all of the appellant's applications, and directed the appeal to proceed to a substantive hearing.
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: medium
The Tribunal held that isolated administrative errors or delay by a party, including a public authority, do not automatically amount to unreasonable conduct warranting costs or draconian sanctions if they are capable of reasonable explanation and do not cause material prejudice; a list of documents served in compliance with rule 27 does not, without amended pleadings, expand the scope of the pleaded case.
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 observed that barring or strike‑out are last‑resort measures requiring persistent or serious non‑compliance and that it lacks jurisdiction in the appeal to adjudicate free‑standing public‑law complaints about HMRC or to treat without‑prejudice settlement discussions as automatically limiting HMRC's arguments.