Munyanga Development Limited v Uganda Revenue Authority
Tax Appeals Tribunal, Application No. 73 of 2026. 30 June 2026.
The ninetieth day
The Revenue Authority decided an objection a few hours too late. The taxpayer had already used the one remedy the law gives for silence.
The situation
A resort operator was assessed UGX 2.6 billion on 22 November 2025 for 2022 to 2024, because revenue in its audited accounts did not match the credits on its bank statements. It objected on 31 December 2025 to UGX 2.45 billion of it. Meetings and document exchanges followed in February and March 2026.
The ninety days ran out on 30 March 2026. On 31 March the company lodged a written election to treat its objection as allowed. Later the same day the Revenue Authority issued its objection decision, allowing UGX 792.2 million and keeping UGX 1.81 billion.
What the law says
The Commissioner General must serve notice of an objection decision within ninety days of receiving the objection (TPC s. 26(6)). If that does not happen, the taxpayer may, by notice in writing, elect to treat the objection as allowed (s. 26(7)), and is treated as served with the decision on the day the election is lodged (s. 26(8)).
The time limit is waived only where a review of the taxpayer's records is necessary to settle the objection and the taxpayer is notified of it (s. 26(9)); the notice of review must itself be given within the ninety days (s. 26(10)).
Where it got stuck
Two arguments for the Revenue Authority, as reported: that under the general Interpretation Act the ninetieth day fell a day later, so its evening decision was in time; and that its ongoing requests for documents had extended the period under s. 26(9).
How it was resolved
The Tribunal held for the taxpayer. The tax law's own rule on counting the period took precedence over the general Interpretation Act; the ninety days had run out; the election took effect when it was lodged and needed no approval from the Commissioner General; and from that moment the Revenue Authority had no power to decide the objection. Its later decision, and the assessment, were void.
What a practitioner takes from it
Diary the ninetieth day from the date the Revenue Authority receives the objection, and keep proof of that date.
Requests for documents do not, by themselves, stop the clock: s. 26(9) needs a review of records and a notice saying so.
If the deadline passes, lodge the election promptly and in writing. The advisers who reported the case stress the same points; check the full ruling before relying on it.
What could change
A deadline both sides can see. If the e-tax portal showed the date an objection was received and the date the ninety days end, neither side would need to argue about counting.