UK case law
Afshin Sajedi & Ors The Commissioners for HMRC
[2026] UKUT TCC 102 · Upper Tribunal (Tax and Chancery Chamber) · 2026
The verbatim text of this UK judgment. Sourced directly from The National Archives Find Case Law. Not an AI summary, not a paraphrase — every word below is the original ruling, under Crown copyright and the Open Government Licence v3.0.
Full judgment
1. The Appellant’s appeal to the UT shall be allowed and the decision of the FTT released on 5 March 2025 ( [2025] UKFTT 297 (TC) ) shall be set aside for material error of law. 2. The decision of the FTT shall be remade and the Appellants’ appeal is allowed against HMRC’s decisions to issue closure notices against them refusing their claims for overpayment relief in respect of Stamp Duty Land Tax (“SDLT”). The Appellants are entitled to overpayment relief in respect of SDLT as claimed. 3. HMRC (“the Respondents”) shall pay the Appellants’ reasonable costs of proceedings in the Upper Tribunal, including preparing their application for permission to appeal to the UT. Upper Tribunal Judge Rupert Jones Dated 29 January 2026