Parwinder Singh Gill v The Commissioners for HMRC
Decision date: 13 August 2026
Neutral citation: [2026] UKFTT 1164 (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 a Personal Liability Notice issued to Mr Parwinder Singh Gill holding him personally liable for deliberate VAT inaccuracies in PSGCL's returns for 01/15–06/19. The Tribunal found, on the balance of probabilities, that Mr Gill acted deliberately to mislead HMRC about the VAT due, drew an adverse inference from his failure to call the company accountant, and upheld the PLN of £1,781,474.60. The appeal was 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
The Tribunal's decision rests on findings that an officer who controls invoicing, regularly checks bank statements and receipts, and oversees business operations can be held personally liable where there is persistent, systematic and sustained under-declaration of VAT over years; such conduct supports an inference of deliberate intent to mislead HMRC. Further, where an available witness (here, the accountant) has possession of highly relevant materials and is not called, an adverse inference may be drawn that their evidence would not have assisted the party who failed to call 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 judgment noted that the appellant's ASD diagnosis was not relied on because no medical evidence was produced, and that even if considered it would not have changed the Tribunal’s finding of competency; it also observed that regular, sustained VAT shortfalls are less plausibly explained by random loss of paperwork than by deliberate conduct. These observations do not appear to be central to the holding.