CDH Investment Bank v Commissioner General — Appeal No. 3 of 2025 (Ruling)

Abstract

This ruling concerns a preliminary objection by the Commissioner General seeking dismissal of CDH Investment Bank’s appeal for failure to file grounds of appeal within the statutory time under section 14 of the Revenue Appeals Tribunal Act. The Respondent initially argued non-payment of the 50% deposit and failure to file grounds of appeal, but later withdrew the first ground. The Tribunal examined whether late filing without prior written application constitutes an irregularity warranting dismissal. Considering the minimal delay, counsel’s temporary absence, and the fact that the Revenue Appeals Tribunal (Procedure) Rules came into force mid-process, the Tribunal held that dismissal would be unjust. The Tribunal exercised discretion under Rule 10 to regularize the late filing and granted the Appellant an extension of time. Directions were issued for continuation of the matter, and both parties were cautioned on future compliance.