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Sampesa Agency Limited vs. Commissioner of Domestic taxes

The Respondent is enjoined in mandatory terms to inform a taxpayer immediately of any invalidity in its objection
notice.

“The Respondent informed the Appellant that its objection notice was fully rejected on account of lack of supporting documents. With respect, we think the Respondent is conflating its functions under section 51(4) and 51(11) of the TPA. Under Section 51 (4), The Respondent is enjoined in mandatory terms to inform a taxpayer immediately of any invalidity in its objection notice. The operative term therein is ‘immediately’. It cannot be that the Respondent does not inform the taxpayer of any invalidity in the objection"
notice and then purport to issue an objection decision”

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