Bajombwe v Uganda Revenue Authority (HCT-01-CV-MA-0097-2024)
Observed later treatment
No later-treatment classification is recorded for this judgment.
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Holding
Held that applicants raised triable issues requiring resolution through trial. The applicants acknowledged an outstanding tax liability of UGX 40,346,406 but contended that business cessation due to non-renewal of their license made continued interest and penalties illegal and unfair. The court cannot determine the merits of this defence at the leave stage without a full trial. Unconditional leave to appear and defend granted.
Outcome
Applicants granted unconditional leave to appear and defend the summary suit
Facts
Uganda Revenue Authority filed a summary suit seeking to recover UGX 200,132,885 from the applicants arising from a Memorandum of Understanding dated 2 October 2018. Under the MOU, the 2nd applicant (Bundibugyo Energy Cooperative Society Ltd) agreed to pay outstanding Value Added Tax liability of UGX 161,385,624 in 12 instalments. The 1st applicant executed a personal guarantee. The 2nd applicant paid 9 instalments totalling UGX 121,039,218, leaving a balance of UGX 40,346,406. The applicants contended that in 2020, the Electricity Regulatory Authority did not renew the 2nd applicant's business license, causing complete business shutdown by 31 March 2021. They argued that accruing interest and penalties after business cessation was illegal and unfair. URA contended that applicants provided no proof of cessation and had no defence.
Issues
- Whether the Applicant should be granted leave to appear and defend Civil Suit No. 62 of 2024
Orders
- The applicant is granted unconditional leave to appear and defend Civil Suit No. 62 of 2024.
- The Applicants/Defendants shall file their respective written statements of defense within 15 days from the date of delivery of this Ruling.
- The costs of this application shall abide the outcome of Civil Suit No. 062 of 2024.
Rules and key headnotes
Legislation cited (3)
Cases cited (7)
- Bunjo v KCB (Uganda) Ltd (Miscellaneous Application No. 174 of 2014)
- Roko Construction Ltd v Ruhweza Transportation & Construction (U) Ltd (Miscellaneous Application No. 831 of 2020)
- M.M.K Engineering v Mantrust Uganda Ltd (High Court Miscellaneous Application No. 128 of 2012)
- Bhaker Kotecha v Adam Muhammed [2002] 1 EA 112
- Maluku Interglobal Trade Agency v Bank of Uganda [1985] HCB 65
- Children of Africa v Sarick Construction Ltd (High Court Miscellaneous Application No. 134 of 2016)
- Magric Water General Hardware Ltd v Abasi Balinda Transporters Ltd (Miscellaneous Application No. 067 of 2021)
Full judgment
The original judgment as reported. Read the original PDF before relying on any passage.