Sunshare Investment Company Limited v Commissioner General Uganda Revenue Authority and Another (Miscellaneous Cause No. 216 of 2023)
Observed later treatment
No later-treatment classification is recorded for this judgment.
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Holding
The High Court lacks jurisdiction to entertain judicial review of tax assessment decisions where the dispute concerns the correctness of assessment methodology, computations, and objection findings. Such matters fall within the exclusive jurisdiction of the Tax Appeals Tribunal under the Tax Appeals Tribunal Act and Tax Procedures Code Act. Application dismissed.
Outcome
Application dismissed for lack of jurisdiction; matter to be pursued before Tax Appeals Tribunal
Facts
Sunshare Investment Company Limited, a beverage manufacturer and petroleum products seller, had its tax for July 2017 to June 2021 assessed, audited, and paid. URA subsequently issued additional assessments totalling UGX 2,464,290,101 for Income Tax and VAT based on bank statements and mobile money transactions of individual employees and suppliers, alleging undeclared revenue of UGX 6,520,488,258. The applicant objected, arguing the assessments were based on third-party accounts not belonging to the company and that expenses and deductions were ignored. After objections were disallowed and Alternative Dispute Resolution rejected, the applicant sought judicial review challenging the procedure and legality of the assessment decision dated 1 August 2023.
Issues
- Whether the High Court has jurisdiction to entertain a judicial review application challenging tax assessment decisions.
- Whether the applicant was required to exhaust alternative remedies under tax legislation before seeking judicial review.
- Whether the dispute concerns procedural impropriety amenable to judicial review or substantive tax assessment matters within the jurisdiction of the Tax Appeals Tribunal.
Orders
- The preliminary objection raised by the Respondents succeeds.
- The dispute concerns taxation decisions, assessment methodology and objection findings arising under tax legislation and the rightful forum with jurisdiction is the Tax Appeals Tribunal.
- Miscellaneous Cause No.216 of 2023 is dismissed.
- Costs of the application are awarded to the Respondents.
Rules and key headnotes
Legislation cited (7)
- Judicature Act Cap.13 s.33
- Judicature Act Cap.13 s.36
- Judicature (Judicial Review) Rules S.I No.11 of 2009 r.3
- Judicature (Judicial Review) Rules S.I No.11 of 2009 r.6
- Tax Appeals Tribunal Act Cap.341 s.14
- Tax Procedures Code Act Cap.343 s.25
- Constitution of the Republic of Uganda art.27
Cases cited (8)
- Ocip Moses and Others v Attorney General and Auditor General (HCMA No. 60 of 2013)
- Commissioner General URA v Zain International BV (CACA No. 11 of 2012)
- ABC Capital Bank and Others v Attorney General and Commissioner General URA (Constitutional Petition No. 14 of 2018)
- Makula International Ltd v His Eminence Cardinal Nsubuga and Another (1982) HCB 11
- Desai v Warsama [1967] EA 351
- Uganda Revenue Authority v Rabbo Enterprises (U) Ltd and Mt Elgon Hardware Ltd (SCCA No. 112 of 2004)
- Manji Consulting Ltd v Commissioner General URA (Miscellaneous Cause No. 184 of 2022)
- Salim Ali Bhai and Others v URA (Miscellaneous Cause No. 123 of 2020)
Full judgment
The original judgment as reported. Read the original PDF before relying on any passage.