Cargills Agrifoods Ltd. Vs. The Commissioner General Of Inland Revenue – 06/2015-2023

Brief
In the case between Cargills Agrifoods Ltd. (formerly “CPC Agrifoods Limited”) and the Commissioner General of Inland Revenue, the court examined whether an appeal “stated as a case” under section 11A(1) of the Tax Appeals Commission Act could be filed prior to or only upon the Tax Appeals Commission’s determination, the legitimacy and curability of the statutory requirement to deposit 25% of the assessed tax (or provide a guarantee) when filing the appeal, and whether procedural refusals to list or re-list the appeal violated natural justice. The Court set aside the Commission’s refusal to list the appeal, finding procedural errors amounted to a denial of fair hearing, and directed that the matter be reheard, relying on statutory interpretation and the principles of audi alteram par