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Asiimwe TA Assy Lodges v Uganda Revenue Authority [2025] UGTAT 3

Tribunal · 2025 Application Granted AI-generated summary ↓ Download Pin to watchlist Add to matter
Jurisdiction
Uganda
Case Type
Application for extension of time to file an application for review of a taxation objection decision
Decision
Extension of time granted to file application for review of taxation objection decision

Observed later treatment

No later-treatment classification is recorded for this judgment.

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Holding

The Tax Appeals Tribunal granted the applicant's application for an extension of time to file an application for review of a taxation objection decision. The Tribunal held that the Alternative Dispute Resolution (ADR) decision of 11 November 2024 was the appropriate taxation decision for calculating the appeal timeframe, not the earlier objection decision of 13 June 2024. Calculating from the ADR decision date, the application for extension fell within the six-month statutory timeframe. The Tribunal found that the applicant demonstrated sufficient reasons for the delay in filing the application for review, including communication difficulties, financial constraints, and participation in the ADR process.

Outcome

Extension of time granted to file application for review of taxation objection decision

Facts

Asiimwe Eunice, operating Assy Lodges in Katuna Town Council, declared and paid income tax of UGX 276,000 for the period 1 July 2021 to 30 June 2022. On 11 October 2023, the Uganda Revenue Authority issued an additional tax assessment of UGX 26,868,000, citing unexplained loans and non-declaration of the landlord's TIN. The applicant objected on 17 March 2024. URA requested supporting documentation on 19 March 2024, which the applicant did not provide due to alleged email access difficulties. URA issued an objection decision on 13 June 2024, disallowing the objection. The applicant applied for Alternative Dispute Resolution on 7 August 2024. Following meetings and submission of additional information, including a loan agreement, the ADR process concluded on 11 November 2024, upholding the additional assessment. The applicant filed this application for extension of time on 14 February 2025, citing financial difficulties and communication problems as reasons for the delay.

Issues

  1. Whether the Applicant may be granted time within which to apply for an extension of time to review the decision by the Respondent.
  2. What remedies are available?

Orders

  • Application for extension of time granted.
  • Each party to bear its own costs.

Rules and key headnotes

Tax Law — Extension of Time — Calculation of Appeal Timeframe — Alternative Dispute Resolution Decision as Taxation Decision
Where a taxpayer pursues Alternative Dispute Resolution (ADR) following an objection decision, and the ADR process provides a comprehensive and final determination of the tax liability involving meetings and submission of additional information, the ADR decision represents the conclusive determination of the tax liability dispute and is the appropriate taxation decision for calculating the appeal timeframe, effectively superseding the preliminary objection decision.
Tax Law — Extension of Time — Sufficient Reason — Factors to Consider
In determining whether to grant an extension of time to file an application for review of a taxation decision, the Tribunal will consider whether the applicant has demonstrated sufficient reasons for the delay, including reasons that prevented the applicant from taking the essential step in time, whether the application was brought promptly, and whether shutting out the appeal would cause injustice, even where the application is unduly delayed.
Tax Law — Extension of Time — Statutory Timeframes — Distinction Between Different Extension Provisions
An extension granted under section 26(4) of the Tax Procedures Code Act to allow a taxpayer to file a late objection against an assessment does not apply to applications for review of taxation decisions before the Tax Appeals Tribunal, which are governed by section 16 of the Tax Appeals Tribunal Act.

Legislation cited (8)

Cases cited (5)

  • Farid Meghani v Uganda Revenue Authority (Miscellaneous Application No. 185 of 2020)
  • FRES Uganda Limited v Uganda Revenue Authority (Miscellaneous Cause No. 67 of 2024)
  • Uganda Revenue Authority v Consolidated Properties Ltd (Civil Appeal No. 31 of 2000)
  • Eco Bus Company Ltd v Uganda Revenue Authority (Miscellaneous Application No. 28 of 2023)
  • Boney Katatumba v Waheed Karim (Supreme Court Civil Appeal No. 27 of 2007)

Full judgment

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The original judgment as reported. Read the original PDF before relying on any passage.

Asiimwe TA Assy Lodges v Uganda Revenue Authority 2025 UGTAT 3 (21 March 2025)
Source: this page presents Wakilii’s issue analysis and metadata for a publicly reported Ugandan judgment. Any AI-generated summary is marked as such. Judgment text is sourced from the Uganda Legal Information Institute (ulii.org). Wakilii is not affiliated with ULII.