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B Zzaman v HMRC

FTT warning over the dangers of using AI

In B Zzaman v HMRC [2025] UKFTT 539 (3 April) the FTT dismissed the taxpayer’s appeal against discovery in respect of High Income Child Benefit Charge (HICBC) and the taxpayer was cautioned for the use of AI to prepare a statement of case which listed cases that were largely irrelevant or wrongly cited.

Mr Zzaman appealed against a discovery assessment for HICBC for 2018/19. He was not in self-assessment. His adjusted net income exceeded the £50 000 HICBC threshold and he was in receipt of child benefit. In April 2021 one HMRC officer identified a loss of tax for 2018/19. In January 2023 a different HMRC officer made a discovery assessment for £2 501.

Mr Zzaman’s ground of appeal were:

  • retrospective legislation in FA 2022 s 97 was unfair and did not apply in his case:...

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