the Inland Revenue Board is conferred with extensive authority to ensure compliance and curb potential revenue losses. This is achieved through the implementation of tax audits, and it is not uncommon for taxpayers to find themselves in disagreement with notices of assessment or additional assessment issued by the IRB due to purported underpayments.
An appeal before the SCIT may be heard either by a panel of three special commissioners or by a single commissioner. Throughout this process, the merits of the appeal will be thoroughly evaluated involving a careful review of records, documentary evidence and testimonies from witnesses. Subsequently, a deciding order will be issued in which the assessment appealed against will either be confirmed or discharged.
A SCIT deciding order may be appealed to the High Court and the Court of Appeal thereafter. However, the courts’ scope of review is confined to assessing the accuracy of the SCIT’s interpretation and application of the law. Factual determinations by the SCIT hold conclusive weight and serve as the foundation upon which the courts evaluate the appeal.In specific situations, a taxpayer might opt to directly file a judicial review application to the High Court to challenge the IRB’s assessment.