Posted By: | November 27, 2020 |

Tax Litigation: Paradigm Shift on Notice of Refusal to Amend Assessment (NORA)

In a recent epochal decision, OANDO SUPPLY & TRADING LTD V FBIR (2001) 4 TLRN 113, the Lagos Zone of the Tax Appeal Tribunal (TAT) headed by Mr. Kayode Sofola, SAN held that taxpayers need not wait indefinitely on the FIRS to issue NORA before filling tax appeals to the TAT. “Unreasonably delay” by the FIRS is deemed to be refusal to revise the assessment as desired by the tax- payer, pursuant to his objection. This piece examines the ramifications of this decision for the tax objection/appeal process in Nigeria, whilst prefacing the discussion with an overview of the tax dispute resolution process, pre and post FIRS (Establishment) Act No. 13, 2007 (FIRS Act).

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