Wakilii

Veeram HJealthcare (U) Limited v Uganda Revenue Authority [2025] UGTAT 6

Tribunal · 2025 Preliminary Objection Dismissed AI-generated summary ↓ Download Pin to watchlist Add to matter
Jurisdiction
Uganda
Case Type
Ruling on preliminary objection to jurisdiction raised by Respondent in tax dispute application
Decision
Preliminary objection dismissed; matter to proceed to hearing on merits

Observed later treatment

No later-treatment classification is recorded for this judgment.

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Holding

The Tax Appeals Tribunal has jurisdiction to hear an application challenging an agency notice issued by the Commissioner General. An agency notice constitutes a taxation decision under section 1(1)(k) of the Tax Appeals Tribunal Act and section 1 of the Tax Procedures Code Act. Not all taxation disputes require an objection decision before being brought before the Tribunal. The issuance of an agency notice involves the exercise of discretion and amounts to a taxation decision over which the Tribunal has jurisdiction.

Outcome

Preliminary objection dismissed; matter to proceed to hearing on merits

Facts

Veeram Healthcare (U) Limited, a pharmaceutical importer, was assessed for PAYE liability of UGX 337,293,801 following a URA audit covering December 2013 to April 2016. URA issued a third-party agency notice in January 2017. After reconciliation meetings in March 2017, the parties agreed the actual liability was UGX 36,556,020, formalized in a Memorandum of Understanding with payment installments. The Applicant complied with the MOU and paid the agreed amounts. URA acknowledged receipt of UGX 35,463,350 in March 2018 and requested a top-up of UGX 2,725,810, which the Applicant paid. However, URA failed to update the e-tax ledger to reflect these payments, causing the liability to continue attracting interest and penalties, creating a false liability of UGX 210,964,838. In March 2022, URA issued another agency notice for UGX 205,013,844, blocking the Applicant's bank accounts. The Applicant filed an application with the Tax Appeals Tribunal. URA raised a preliminary objection that the application was not properly before the Tribunal because the Applicant had not obtained an objection decision before filing.

Issues

  1. Whether the instant application is properly before the Tax Appeals Tribunal without an objection decision from the Commissioner.

Orders

  • Preliminary objection dismissed with costs.
  • Tribunal to proceed to hear the main application on its merits.

Rules and key headnotes

Tax Law — Jurisdiction of Tax Appeals Tribunal — Taxation Decision — Agency Notice
An agency notice issued by the Commissioner General under section 29 of the Tax Procedures Code Act constitutes a taxation decision within the meaning of section 1(1)(k) of the Tax Appeals Tribunal Act and section 1 of the Tax Procedures Code Act, over which the Tax Appeals Tribunal has jurisdiction.
Tax Law — Objection Procedure — Requirement for Objection Decision — Taxation Decision Distinguished
Not all taxation disputes require an objection decision before being brought before the Tax Appeals Tribunal. A taxation decision is distinct from an objection decision, and where the Commissioner General exercises discretion to issue an agency notice, this amounts to a taxation decision that may be challenged directly before the Tribunal.
Statutory Interpretation — Literal Rule — Definition of Taxation Decision
Applying the literal rule of statutory interpretation, a taxation decision under section 1(1)(k) of the Tax Appeals Tribunal Act and section 1 of the Tax Procedures Code Act includes any assessment, determination, decision or notice, and encompasses decisions made in the exercise of the Commissioner General's discretion.
Administrative Law — Exercise of Discretion — Taxation Decision
The making of a decision involves the exercise of discretion. Where the Commissioner General exercises discretion to issue an agency notice under section 29 of the Tax Procedures Code Act, this constitutes a taxation decision capable of being challenged before the Tax Appeals Tribunal.

Legislation cited (7)

Cases cited (9)

  • Mobitex Engineering Co. Works Ltd v Uganda Revenue Authority (TAT Application No. 91 of 2023)
  • Century Bottling Company Ltd v Uganda Revenue Authority (TAT Application No. 33 of 2010)
  • Cable Corporation (U) Ltd v Uganda Revenue Authority (Civil Appeal No. 1 of 2011)
  • Alpha Woolen (U) Ltd v Uganda Revenue Authority (Application No. 40 of 2023)
  • Lotus Technologies v Uganda Revenue Authority (TAT Application No. 250 of 2022)
  • Kawuki Mathias v Uganda Revenue Authority (Misc. Cause No. 14 of 2015)
  • Gakou Brothers Enterprises Ltd v Uganda Revenue Authority (Application No. 29 of 2020)
  • Cable Corporation (U) Ltd v Uganda Revenue Authority (Civil Appeal No. 1 of 2011)
  • Republic v Kenya Revenue Authority; Exparte: Krystalline Salt Limited; Judicial Review Application No. 359 of 2018

Full judgment

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

Veeram HJealthcare (U) Limited v Uganda Revenue Authority 2025 UGTAT 6 (1 April 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.