30.     Objections

            (1) A person dissatisfied with an appealable decision may lodge an objection to the decision with the Commissioner General within 30 days after service of the notice of the decision.

            (2) Upon application in writing by a person dissatisfied with an appealable decision, the Commissioner General may, where satisfied that owing to absence from Botswana, sickness, or other reasonable cause, the person was prevented from lodging an objection to the decision within the time specified under subsection (1) and there has been no unreasonable delay by the person in lodging the objection, accept an objection lodged after the time specified under subsection (1).

            (3) An objection to an appealable decision shall be in writing and specify in detail, the grounds upon which it is made.

            (4) In the case of an objection to an assessment, the Commissioner General may consider the objection only if-

     (a)     the person assessed has paid the tax due under the assessment; or

     (b)     the Commissioner General is satisfied that the person objecting is unable to pay the full amount of tax due and has given sufficient security for the amount of tax unpaid and any penalty that may become payable.

            (5) After considering the objection, the Commissioner General may allow the objection in whole or in part and amend the assessment or the decision objected to accordingly, or disallow the objection.

            (6) The Commissioner General shall serve the person objecting with notice in writing of the decision on the objection.

            (7) A person dissatisfied with a decision of the Commissioner General under subsection (2) may appeal against the decision only in accordance with the provisions of this Part.

31.     Appeals

            (1) In this section-

            "Board of Adjudicators" means a board appointed by the Minister to hear any matter in dispute between the Commissioner General and any person in respect of the person's liability or assessment for tax.

            (2) A person dissatisfied with a decision under section 30(5) may, within 30 days after the person was served with notice of the decision, lodge with the Commissioner General, a notice of appeal to the High Court or, at the person's option, the Board of Adjudicators.

            (3) Upon application in writing by a person dissatisfied with a decision under section 30(5), the Commissioner General may, where satisfied that owing to absence from Botswana, sickness, or other reasonable cause, the person was prevented from lodging a notice of appeal within the time specified under subsection (2) and there has been no unreasonable delay by the person in lodging the notice, accept a notice of appeal lodged after the time specified under subsection (2).

            (4) The provisions of sections 90-94, except for section 91(3), and except for the time period to lodge an appeal under section 91(2)(c) of the  Income Tax Act and any regulation made under that Act relating to the High Court or the Board of Adjudicators and to any appeal in terms of section 93 of that Act, shall apply with necessary changes made to adapt those rules to a value added tax appeal.

            (5) A person dissatisfied with a decision of the Commissioner General under subsection (3) may appeal against the decision only in accordance with the provisions of this Part.

32.     Burden of proof

            The burden of proving that an assessment is excessive or that a decision of the Commissioner General is wrong is on the person objecting to the assessment or decision.