Alert
The thirty-day objection window is jurisdictional, and it is missed constantly
A late objection to a FIRS assessment cannot be cured by agreement, correspondence, or an officer who says it is fine.
A taxpayer served with a notice of assessment has thirty days to object. The period runs from service, not from the date the assessment was signed, and not from the date the finance team noticed it in the post tray.
Objections filed outside that window are routinely rejected, and the Tax Appeal Tribunal has consistently held that it lacks jurisdiction to hear an appeal founded on an objection that was itself out of time.
Why it is missed
Three failures produce nearly all the late objections we see.
Service is effected at a registered address the company no longer uses. The Federal Inland Revenue Service is entitled to serve at the address on the record, and a company that has moved without updating it has been validly served whether or not anyone read the notice.
The assessment reaches a finance team that treats it as a bill to be queried informally. Weeks of correspondence with the assessing officer follow, none of which stops time.
Or the deadline is calculated from the wrong date. It is thirty days from service. A notice dated the 3rd and served on the 19th gives until the 18th of the following month, not the 2nd.
What an objection has to contain
A valid notice of objection states the grounds, the amount the taxpayer contends is correct, and the amount not in dispute. An objection that simply disputes the assessment without particulars is liable to be treated as no objection at all.
The amount not in dispute should be paid. Withholding it does not strengthen the objection and it exposes the taxpayer to interest and penalties on a sum it has effectively conceded.
If the window has closed
The position is not always hopeless. Where service was defective, time has not started to run, and the defect is worth examining before the objection is abandoned. Where the assessment is a nullity on its face, it can be challenged on a different footing.
Both routes are considerably harder than filing on time.