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K.K Electrical Company v Uganda Revenue Authority (Miscellaneous Cause No. 18 of 2025)

High Court · [2026] UGHCCD 110 · 2026 Application Dismissed AI-generated summary ↓ Download Pin to watchlist Add to matter
Jurisdiction
Uganda
Case Type
Application for judicial review of URA objection decision dismissing tax assessment objection
Decision
Application dismissed for lack of jurisdiction

Observed later treatment

No later-treatment classification is recorded for this judgment.

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Holding

The High Court dismissed the application for judicial review of a URA tax objection decision on jurisdictional grounds. Held that under Article 152(3) of the Constitution and section 14 of the Tax Appeals Tribunal Act, original jurisdiction to review taxation decisions and objection notices lies with the Tax Appeals Tribunal, not the High Court. The High Court exercises only appellate jurisdiction over decisions of the Tax Appeals Tribunal. The application was misconceived and an abuse of court process.

Outcome

Application dismissed for lack of jurisdiction

Facts

K.K Electrical Company was issued an income tax assessment by URA for the period 01.02.2022 to 30.06.2023 totalling UGX 229,995,048. On 01.03.2025, the Applicant lodged an objection. URA requested supporting documents including financial statements, salary and wage ledgers, payment vouchers, and pay slips. On 20.05.2025, before the Applicant submitted the requested documents, URA issued an objection decision (Refusal No. 45524135) upholding the assessment on grounds of insufficient documentation. The Applicant filed for judicial review seeking certiorari to quash the objection decision and mandamus to compel URA to reconsider the objection after reviewing the documents. URA raised a preliminary objection that the High Court lacked original jurisdiction and that the Applicant had not exhausted statutory remedies.

Issues

  1. Whether the High Court has original jurisdiction to hear an application for judicial review of a tax objection decision.
  2. Whether the application is amenable to judicial review where statutory remedies have not been exhausted.

Orders

  • Application dismissed.
  • Costs awarded to the Respondent.

Rules and key headnotes

Judicial Review — Jurisdiction — Tax Matters — Original Jurisdiction of Tax Appeals Tribunal
Under Article 152(3) of the Constitution and section 14 of the Tax Appeals Tribunal Act Cap 341, original jurisdiction to review taxation decisions, notices, and objection decisions lies with the Tax Appeals Tribunal, not the High Court. The High Court exercises only appellate jurisdiction over decisions of the Tax Appeals Tribunal.
Tax Procedures — Objection Decisions — Statutory Remedy
Where a taxpayer is dissatisfied with an objection decision issued by the Uganda Revenue Authority, the lawful remedy under section 27 of the Tax Procedures Code Act Cap 343 is to apply to the Tax Appeals Tribunal for review of the objection decision within thirty days, not to seek judicial review in the High Court.
Amenability to Judicial Review — Exhaustion of Statutory Remedies
A court cannot assume jurisdiction which it does not have. Jurisdiction must be conferred by statute or the Constitution. Where a statute provides a specific remedy and forum for challenging administrative decisions, an applicant must exhaust those statutory remedies before seeking judicial review in a court lacking original jurisdiction over the subject matter.

Legislation cited (10)

Cases cited (3)

  • Dai Us Warfln (1961) A 351
  • Uganda Revenue Authority v Ratu Enterprises (U) Ltd (Appeal No. 12 of 2004)
  • Makula International Limited Vs His Eminence Cardinal Nsubuga & Anor 1982 HCB 11

Full judgment

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

K.K Electrical Company v Uganda Revenue Authority (Miscellaneous Cause No. 18 of 2025) [2026] UGHCCD 110 (31 March 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.