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Surjit Singh Rai v The Commissioners for HMRC [2026] UKFTT 404 (TC)


1st April 2026


🔍 Key Takeaway from Recent Tax Tribunal Decision Allowing New Legal Grounds in a £2M+ Case

 

The First-tier Tribunal has approved an application to introduce two new legal grounds in a significant securities transaction case involving a tax assessment of over £2 million.

The decision highlights the tribunal's focus on fairness and the public interest in taxpayers paying the correct amount of tax. Importantly, it reaffirms that late legal arguments, especially questions of law, can be admitted if they have a real prospect of success and are relevant to the case.

 

Despite concerns around delays, the tribunal emphasised flexibility in legal proceedings to ensure just outcomes. This ruling underscores the importance of a fair and pragmatic approach in tax disputes.

A reminder of the tribunal’s role in balancing procedural rules with the pursuit of accurate tax assessments. 

 

Keith Gordon and Siobhan Duncan successfully represented the Appellant.

 

 


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