Singh v Revenue and Customs (COSTS - appellant's application for unreasonable costs - late withdrawal by HMRC - whether HMRC acted unreasonably in defending proceedings - whether earlier "costs of and incidental to" appeal - whether costs claimed reasonable and proportionate) [2026] UKFTT 46 (TC) (06 January 2026)

Singh v Revenue and Customs (COSTS - appellant's application for unreasonable costs - late withdrawal by HMRC - whether HMRC acted unreasonably in defending proceedings - whether earlier "costs of and incidental to" appeal - whether costs claimed reasonable and proportionate) [2026] UKFTT 46 (TC) (06 January 2026)

HMRC acted unreasonably in a limited respect by failing to withdraw from the appeal at an earlier stage after being on notice of the appellant's evidence, but the majority of the costs claimed were not reasonably incurred, not incidental to the proceedings, or disproportionate. No uplift is justified. Only a portion of the claimed costs is allowed, limited to reasonable and proportionate costs incurred after January 2024.

Citation
[2026] UKFTT 46 (TC)
Parties
Appellant: Hardev Singh; Respondents: The Commissioners for His Majesty's Revenue and Customs
Jurisdiction
United Kingdom
Judgment Date
06 January 2026
Procedural Posture
Tax Costs Application / Post Withdrawal Costs Determination
Outcome
Application for costs allowed in part
Legal Topics
Costs, Unreasonable Conduct, Litigant in Person, Tribunal Procedure, Summary Assessment
Tax Law Civil Procedure Costs Unreasonable Conduct Litigant in Person Tribunal Procedure Summary Assessment

Case Brief

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Parties

Hardev Singh

Appellant

The Commissioners for His Majesty's Revenue and Customs

Respondents

Procedural Posture

Tax Costs Application / Post Withdrawal Costs Determination

Legal Issues

  1. 1 Whether HMRC acted unreasonably in defending proceedings and/or withdrawing late
  2. 2 Whether costs claimed are of and incidental to the appeal
  3. 3 Whether costs claimed are reasonable and proportionate

Ratio Decidendi

HMRC acted unreasonably in a limited respect by failing to withdraw from the appeal at an earlier stage after being on notice of the appellant's evidence, but the majority of the costs claimed were not reasonably incurred, not incidental to the proceedings, or disproportionate. No uplift is justified. Only a portion of the claimed costs is allowed, limited to reasonable and proportionate costs incurred after January 2024.

Court Disposition

Application for costs allowed in part

Orders

  • HMRC to pay the appellant a reduced sum representing reasonable and proportionate costs incurred after January 2024, assessed on a summary basis.