The appellant, Nazrul Islam, appealed against an assessment issued by HMRC for £19,981.47 for the tax year ending 5 April 2021 related to payments made under CJRS.

Employees could only claim the CJRS for furloughed employees for whom HMRC received PAYE Real Time Information (RTI) in the form of a full payment submission (FPS) by specific dates.

Islam was the director of Top-Notch Accountants Limited, which was incorporated on 5 January 2017 and provided accounting and auditing services, bookkeeping, and tax consultancy.

The employee in question was appointed as an account manager on 20 December 2019. He was later reappointed as company secretary on 22 March 2020 in addition to that role.