The Respondent is only enjoined in law to consider and issue an objection decision in respect of a valid objection lodged in time.

The Respondent is only enjoined in law to consider and issue an objection decision in respect of a valid objection lodged in time. This is provided for under Section 51 (8) of the Tax Procedures Act: The taxpayer failed to provide documents to support its application for extension of time to file an objection out of time. The Tribunal having determined that the notice of objection was invalid did not delve into the issue that remained for its determination as it had been rendered moot.