Tax Law · First-tier Tribunal (Tax)
Sanjaykumar Vadera v The Commissioners for HMRC
Checked against the judgment on 20 August 2026 · how we verify
Facts
On 9 December 2020 Mr Sanjaykumar Vadera acquired Apartment 6.03, together with Storage Unit 2 and Car Parking Space 32, at 20 Grosvenor Square, London for £29,000,000, and an SDLT return submitted on 11 December 2020 was accompanied by payment of SDLT of £4,248,750. On 5 January 2023 Cornerstone Tax 2020 Limited, acting for him, claimed overpayment relief of £2,809,250 on the basis that the transaction was not wholly residential; HMRC rejected the claim, and Cornerstone lodged a notice of appeal on 21 December 2023. The appeal was stayed behind lead appeals concerning other properties in the same development. Administrators were appointed to Cornerstone on 11 September 2024. The Tribunal directed on 4 September 2025 that the Appellant confirm by 18 September 2025 whether he wished to continue, sent a reminder on 8 October 2025, and issued an unless order on 27 October 2025 requiring confirmation by 10 November 2025; none was answered, and on 13 November 2025 the appeal was automatically struck out under Rule 8(1) of the Tribunal Procedure (First-tier Tribunal) (Tax Chamber) Rules 2009. On 26 November 2025 the Appellant applied for reinstatement, which HMRC opposed by Notice of Objection dated 22 January 2026.
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