Principle(s):

To the effect that timelines and fees set by statuses are matters of substantive law and not mere technicalities and must be strictly complied with.

The application of O. 51 rule 4 of the Civil Procedure Rules in taxation proceedings.

Brief facts:

On 21st September 2015, the respondent issued the applicant with an administrative income tax assessment of Shs. 32,245,292 for the period of March 2013 being the additional amount assessed under PAW to balance the Applicant’s ledger. On 2nd November 2015, the Applicant objected and on 12th January 2016 the respondent issued its objection decision disallowing the objection. On 20th January 2023, the applicant lodged this application for review of the objection decision. At scheduling counsel for the respondent raised 2 preliminary objections. 

Holding:

It was held that the application should be rejected by the Tribunal as being time barred and for non-payment of the 30%.