The tax laws prescribe strict statutory deadlines, which apply equally to taxpayers and the tax authority,

A Mabeya

"In this Court’s view, the respondent having failed to notify the appellant of the alleged invalidity of the objection within 14 days, he is deemed to have considered it to be valid and was bound to render his objection decision within 60days of 11/11/2019. It does not matter that the appellant heeded the illegal call of having to submit the documents after the 11/1/2019. Two wrongs do not make a right.

Accordingly, the Tribunal erred by failing to consider that the respondent did not communicate to the appellant of the alleged invalidity of its objection within the timelines set by the law. The strict timelines set by the tax laws are to be complied with by both the tax payer and the tax authority. The Commissioner cannot be allowed to arrogate himself the discretion to extend time within which he has to act."