In Munyanga Development Limited v Uganda Revenue Authority (URA) (TAT Application No. 73 of 2026), the Tax Appeals Tribunal considered:

  1. whether or not a taxpayer’s election to treat its tax objection as allowed was valid after URA failed to serve an objection decision within the mandatory 90-day period; and
  2. whether or not URA retained the jurisdiction to issue an objection decision after such an election had been lodged.

The taxpayer argued that URA failed to serve an objection decision within the mandatory 90-day period under Section 26(6) of the TPCA.  This expired on 30th March 2026 (90-day period commencing from the day the objection was submitted). Having received no decision, the taxpayer lodged an election on the morning of 31st March 2026, automatically deeming the objection allowed under Section 26(8).

URA argued -that under the Interpretation Act, the 90-day count excludes the objection date, making 31st March 2026; the 90th day. URA further argued that ongoing document requests implied an extension of the timeline under Section 26(9) and validated its objection decision issued later that evening.

Ruling: The Tribunal agreed with the taxpayer, ruling that the specific time-computation rules of the tax law take precedence over general statutory interpretation laws. The Tribunal affirmed that the 90-day period had expired, rendering the taxpayer’s election valid and immediately effective by law. Crucially, the Tribunal clarified that the Commissioner General's approval, consent, or agreement is not required once an election is submitted; the legal resolution is automatic and does not depend on URA's permission.

Practical illustration: For example, an objection filed on 31st December 2025 makes 31st December Day 1. Counting through January (31 days), February (28 days), and March (30 days), the 90-day deadline officially expires on 30th March 2026. If URA serves no decision by then, the taxpayer can file an election notice on 31st March 2026 (Day 91) to automatically treat the objection as allowed.

Key outcome: URA exhausted its mandate and lost legal authority over the matter the moment the election was lodged, rendering its subsequent decision and the resulting UShs. 1,808,625,194 assessment null, void, and unenforceable.

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