Parvaiz Akhtar v The Commissioners for HMRC

Parvaiz Akhtar v The Commissioners for HMRC

HMRC's assessments were made to best judgment based on all material available, were not arbitrary or unreasonable, and the appellant failed to provide sufficient evidence to displace the quantum of the assessments.

Parties
Appellant: Parvaiz Akhtar; Respondents: The Commissioners for His Majesty’s Revenue and Customs
Jurisdiction
England and Wales
Judgment Date
23 September 2025
Procedural Posture
VAT Assessment Appeal / First Tier Tribunal Judgment
Outcome
Appeal dismissed
Legal Topics
VAT Assessments, Best Judgment Assessments, Record Keeping Requirements, Burden of Proof, Quantum of Assessment
Tax Law VAT Assessments Best Judgment Assessments Record Keeping Requirements Burden of Proof Quantum of Assessment

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Parties

Parvaiz Akhtar

Appellant

The Commissioners for His Majesty’s Revenue and Customs

Respondents

Procedural Posture

VAT Assessment Appeal / First Tier Tribunal Judgment

Legal Issues

  1. 1 Whether HMRC's VAT assessments were made to best judgment under s73 VATA 1994
  2. 2 Whether the appellant displaced the assessments by showing they were incorrect

Ratio Decidendi

HMRC's assessments were made to best judgment based on all material available, were not arbitrary or unreasonable, and the appellant failed to provide sufficient evidence to displace the quantum of the assessments.

Court Disposition

Appeal dismissed

Orders

  • Assessments upheld in full