Registerd Trustees of Association of Jehova's Witness of Malawi vs Malawi Revenue Authority

Abstract

This case concerns an appeal by the Registered Trustees of the Association of Jehovah’s Witness of Malawi against the Malawi Revenue Authority (MRA) regarding the extension of time to lodge an appeal against a decision made by a Special Arbitrator under section 98 of the Taxation Act. The main issues involve whether the lower court or the Arbitrator had jurisdiction to extend time, the correctness of the courts' interpretation of procedural laws, and the applicability of principles such as functus officio and res judicata. The High Court affirmed that the extension of time was properly granted, clarified the procedural framework governing appeals from the Special Arbitrator to the High Court under the Taxation Act, and dismissed the appeal on merits, emphasizing the importance of adhering to legal procedures in tax disputes. The court also highlighted that the application was solely to extend time for appeal and did not re-open issues on the merits, reaffirming procedural correctness and jurisdictional authority