Rai v Revenue and Customs [2026] UKFTT 404 (TC) (18 March 2026)

Rai v Revenue and Customs [2026] UKFTT 404 (TC) (18 March 2026)

The application to amend the grounds of appeal is refused. The application was made very late, after the parties had served lists of documents and witness evidence, and after the original hearing window was lost. There is no good explanation for the delay, and the new grounds could and should have been raised earlier. Allowing the amendments would cause further delay, additional cost, and undermine finality and proper case management. The balance of fairness and efficiency, applying the principles from Quah, CNM Estates, and Exchequer Solutions, weighs against granting the application. The tribunal's duty to determine the correct amount of tax does not override the need for procedural...

Citation
[2026] UKFTT 404
Parties
Appellant: Mr Surjit Singh Rai; Respondents: The Commissioners for His Majesty's Revenue and Customs
Jurisdiction
United Kingdom
Judgment Date
18 March 2026
Procedural Posture
Tax Appeal / Interlocutory Application to Amend Grounds of Appeal
Outcome
Application to amend grounds of appeal refused
Legal Topics
Transactions in Securities, Income Tax Act 2007, Amendment of Grounds of Appeal, Procedural Fairness, Case Management
Tax Law Transactions in Securities Income Tax Act 2007 Amendment of Grounds of Appeal Procedural Fairness Case Management

Case Brief

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Parties

Mr Surjit Singh Rai

Appellant

The Commissioners for His Majesty's Revenue and Customs

Respondents

Procedural Posture

Tax Appeal / Interlocutory Application to Amend Grounds of Appeal

Legal Issues

  1. 1 Whether the appellant should be permitted to amend his grounds of appeal to add two new grounds (the s 687(2) ground and the s 685(6) ground)
  2. 2 Whether the application to amend is 'late' or 'very late' and the consequences for case management and fairness
  3. 3 Whether the new grounds are pure questions of law or require further evidence

Ratio Decidendi

The application to amend the grounds of appeal is refused. The application was made very late, after the parties had served lists of documents and witness evidence, and after the original hearing window was lost. There is no good explanation for the delay, and the new grounds could and should have been raised earlier. Allowing the amendments would cause further delay, additional cost, and undermine finality and proper case management. The balance of fairness and efficiency, applying the principles from Quah, CNM Estates, and Exchequer Solutions, weighs against granting the application. The tribunal's duty to determine the correct amount of tax does not override the need for procedural...

Court Disposition

Application to amend grounds of appeal refused

Orders

  • The appellant is not permitted to amend his grounds of appeal to add the s 687(2) and s 685(6) grounds.
  • The appeal will proceed on the existing grounds only.