Summary of ruling
- The Applicant deals in real estate, specifically leasing of commercial office space
- Following a tax audit for the period of 1st January 2017 to 31st December 2020, the Respondent issued additional income tax assessment to the tune of Ushs. 3,528,910,176 citing undeclared income, over-claimed expenses and overclaimed IBD.
- The Applicant’s objection was disallowed. The Applicant subsequently applied for ADR.
- The ADR was disallowed hence the Application.
- The Applicant provided new information during ADR which was reviewed. Hence, the ADR decision is the final tax decision which should be appealed to TAT.
- The Applicant did not discharge the burden of proving each expense hence the Application is dismissed.
