In a decisive ruling on Friday, High Court Judge Gino Persaud found that the Guyana Revenue Authority (GRA) overstepped its legal authority by attempting to reassess taxes on imports after they had been cleared and initial duties paid. This judgment effectively blocks the GRA’s claim for an additional GY$421 million in taxes on businessman Azruddin Mohamed’s 2020 Lamborghini and other luxury vehicles.
Judge Persaud held that once goods have been legally entered, cleared, and taxed, the GRA lacks any statutory power under the Customs Act or its Fifth Schedule to impose further assessments. The ruling, delivered on the fixed date application filed by Mohamed in April 2025, drew on precedents cited by Mohamed’s legal team, underscoring the illegitimacy of post-clearance reassessments by the tax authority.
Mohamed’s lawyer, Siand Dhurjon, confirmed that the judge also ruled the GRA could only pursue additional taxes through criminal proceedings under the Customs Act—proceedings that have since collapsed. In fact, the Director of Public Prosecutions withdrew the criminal charges of false declaration and tax evasion on Mohamed’s Lamborghini following a US extradition request against him.
The court granted Mohamed’s full suite of relief, declaring the GRA’s tax demands—amounting to GY$371,775,168 on the Lamborghini and GY$24,641,272 each on two Toyota Land Cruisers—“arbitrary, ultra vires, unreasonable, unfair and unlawful.” It also quashed the GRA’s demand for surrender of these vehicles to its Law Enforcement and Investigative Division.
Judge Persaud further restrained the GRA and its agents from seizing the vehicles and ordered the authority to pay Mohamed GY$750,000 in costs by December 31, 2025. This comes in addition to an outstanding GY$300,000 previously awarded by the Full Court.
The judge was notably critical of the GRA’s repeated attempts to delay justice, dismissing multiple last-minute filings as “an abuse of the court’s process.” Among these was a November 5 application by the GRA to introduce extradition proceedings into the tax case, which the judge deemed irrelevant to the core issue of whether the tax reassessments were lawful.
The ruling also rejected the GRA’s attempt to suspend proceedings pending resolution of criminal charges—an effort the judge viewed as an unfounded tactic to stall. The court admonished the GRA for flooding the case with no fewer than five affidavits in defense, a procedural strategy the judge found improper and contrary to Civil Procedure Rules.
Mohamed’s legal team praised the judgment as “most considered and strong,” highlighting the GRA’s reliance on an extensive legal team of over ten attorneys, including Senior Counsel Anand Ramlogan and Robin Stoby.
This ruling sends a clear message that the GRA’s aggressive tax reassessment and procedural maneuvers will not go unchecked, emphasizing the limits of administrative power and the need for transparency and fairness in taxation.
