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Farm Inputs Care Center (FICA) Limited v Uganda Revenue Authority [2026] UGTAT 20

Tribunal · 2026 Application Dismissed 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 decision
Decision
Application for extension of time dismissed

Observed later treatment

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Holding

The Tax Appeals Tribunal dismissed the application for extension of time to file an application for review of a taxation decision. The Tribunal held that the Applicant failed to demonstrate sufficient cause for the 14-month delay, finding that the Applicant's reliance on alleged negligence by a tax consultant was unsubstantiated and that the Applicant failed to act promptly upon discovering the consultant's alleged failure. Statutory timelines in tax matters are substantive law and must be strictly complied with.

Outcome

Application for extension of time dismissed

Facts

The Applicant, a seed multiplication and processing company, was issued VAT and Income Tax assessments by the Respondent in April 2024. The Applicant objected, and on 21 August 2024, the Respondent issued an objection decision disallowing the VAT objection. The Applicant claims it instructed a tax consultant, Mr. Noah Kirabo, to file an application for review with the Tax Appeals Tribunal, believing he had done so. On 15 December 2024, the Applicant discovered the tax liability remained on the ledger. On 31 December 2024, the Applicant filed TAT Application No. 004 of 2025, which was dismissed on 18 September 2025 for being filed out of time without leave. On 29 September 2025, the Applicant filed this application for extension of time to file an application for review, approximately 14 months after the objection decision was issued.

Issues

  1. Whether there is sufficient cause to grant extension of time to file an application for review of a tax decision?
  2. Whether the Applicant is barred from filing a fresh application after dismissal of TAT Application No.4 of 2025?

Orders

  • The application for extension of time is hereby dismissed.
  • Each party to bear its own costs.

Rules and key headnotes

Tax Appeals — Extension of Time — Sufficient Cause
An applicant seeking extension of time to file an application for review of a taxation decision must demonstrate sufficient cause for the delay. Good cause relates to factors which caused inability to file within the prescribed period and includes consideration of the length of delay, the reason for delay, the possibility of success, and the degree of prejudice to the other party.
Tax Appeals — Statutory Timelines — Substantive Law
Timelines set by statutes for filing tax appeals are matters of substantive law and not mere technicalities and must be strictly complied with. Time limits are there to be observed and justice may be defeated if there is laxity.
Agency — Negligence of Agent — Burden on Principal
A principal is generally bound by the acts of their agent. Inordinate delay and negligence to observe or ascertain plain requirements of the law are not mistakes of an advocate from which a client can be excused. An affidavit stating that an agent was instructed, without corroborating evidence such as an engagement letter or correspondence, is insufficient to discharge the burden of explaining delay.
Tax Appeals — Extension of Time — Discretion of Tribunal
The Tax Appeals Tribunal may, upon application in writing, extend time for making an application for review of a taxation decision. The Tribunal must exercise its discretion judicially to avoid injustice or hardship resulting from accident, inadvertence or excusable mistake, but not to assist a person who has deliberately sought to obstruct or delay the cause of justice.

Legislation cited (7)

Cases cited (10)

  • Farid Meghan v Uganda Revenue Authority (High Court Civil Appeal No. 06 of 2021)
  • Seah Mugaadya v Uganda Revenue Authority (Miscellaneous Application No. 1056 of 2025)
  • Lifeway Pharmaceutical Industries Limited v Uganda Revenue Authority (Tax Appeals Tribunal Miscellaneous Cause No. 32 of 2025)
  • Tight Security Limited v Chartis Uganda Insurance Company Ltd (Miscellaneous Application No. 8 of 2024)
  • Africa Renewal Ministries Limited v Uganda Revenue Authority (Miscellaneous Application No. 93 of 2022)
  • Shah v Mbogo and another [1967] EA 116
  • Tight Security Limited v Chartis Uganda Insurance Co. Limited (Miscellaneous Application No. 8 of 2014)
  • Mulindwa George William v Kisubika Joseph (Civil Appeal No. 12 of 2014)
  • Kalyesubula v Bank of Africa & Another (Miscellaneous Application No. 944 of 2022) [2024] UGCommC 41
  • Uganda Revenue Authority v Uganda Consolidated Properties Ltd (Court of Appeal Civil Appeal No. 75)

Full judgment

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

Farm Inputs Care Center (FICA) Limited v Uganda Revenue Authority 2026 UGTAT 20 (16 April 2026)
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.