https://new.kenyalaw.org/akn/ke/judgment/ketat/2026/261

 REPUBLIC OF KENYA IN THE TRIBUNAL OF KENYA AT NAIROBI COUNTY COURT NAME: TAX APPEALS TRIBUNAL CASE NUMBER: TATC/E1180/2025 KENYA HOLDINGS LTD VS KENYA REVENUE AUTHORITY JUDGMENT # BACKGROUND 1. Appellant is a limited liability company registered under the laws of Kenya, its principal activity is property ownership, investment in shares and fixed deposits. 2. The Respondent is a principal officer appointed under Section 13 of the Kenya Revenue Authority Act, CAP 469 of Kenya’s Laws (hereinafter “the Act”). Under Section 5 (1) of the Act, the Kenya Revenue Authority is an agency of the Government for the collection and receipt of all tax revenue. Further, under Section 5(2) of the Act with respect to the performance of its functions under subsection (1), the Authority is mandated to administer and enforce all provisions of the written laws as set out in Part 1 and 2 of the First Schedule to the Act for the purposes of assessing, collecting and accounting for all revenues in accordance with those laws. 3. The Respondent informed the Appellant of an intention to audit its books and operations for the period January 2019 to December 2023 through a letter dated 24 October 2024 after which it issued the Appellant with notices on 9th April 2025 and issued additional assessments on 18th June 2025 after review of the Appellant’s VAT returns for May and June 2024, following which additional assessments were raised disallowing input VAT. 4. The Appellant objected to the assessment on 17th July 2025 and the Respondent issued its Objection decision dated 10th September 2025. 5. Dissatisfied with the Respondent’s tax decision the Appellant filed a notice of appeal dated and filed 9th October 2025. # THE APPEAL 1. The Appellant lodged its Memorandum of appeal dated and filed on 22 nd October 2025 filed on even date raising the following grounds of appeal that; 1. The Respondent erred in fact an in law by assessing Withholding Tax (WHT) on deemed dividends on monies loaned to a related party. 2. The Respondent erred in fact and in law by charging WHT on deemed dividend amounts which have been and in future will be subjected to WHT on interest income, thus double taxation being applied to the same amount. # THE APPELLANT’S CASE 1. The Appellant case was premised on its Statement of facts dated and filed on 22nd October, 2025 and Appellant’s submissions dated and filed on 31st March 2026. 2. The Appellant stated that the Respondent informed it of an intention to audit its books and operations for the period January 2019 to December 2023 through a letter dated 24th October 2024 3. The Appellant stated that it requested for an extension of time to 07 th November 2024 to submit the requested documents and the Respondent granted the extension as evidenced by the annexed email 4. The Appellant stated that the Respondent conducted an initial audit interview and that the requested documents were shared on 13th November 2024, with further submissions made between 13th November 2024 and 21th February 2025 as confirmed by email correspondence 5. The Appellant stated that the Respondent issued a notice of intention to raise additional assessments dated 09th April 2025 and further stated that it responded to the pre-assessment notice via email dated 14 May 2025 providing explanations and information. 6. The Appellant stated that the Respondent issued a tax decision for the years 2019 to 2023 through a letter dated 18 June 2025 upon completion of the audit. 7. The Appellant stated that it partially conceded to the tax decision in respect of Corporation Tax, VAT and Withholding Tax on professional fees and requested a payment plan through a letter dated 17 July 2025. 8. That it has honoured the payment plan by remitting taxes on 17 July 2025, 17 August 2025, 17 September 2025 and 17th October 2025 and undertook to complete the remaining payments due on 17th November 2025 and 17th December 2025 9. That it objected to the tax decision specifically on the issue of default assessment on deemed dividends on 17th July 2025 through the iTax system and received an acknowledgment receipt 10. That the Respondent issued an Objection Decision through a letter dated 10 September 2025. 11. The Appellant stated that the Respondent erred in fact and law by assessing Withholding Tax on deemed dividends arising from monies loaned to a related party. 12. The Appellant stated that the Respondent erroneously treated monies advanced as a loan to a third party as deemed dividends despite the existence of a valid loan agreement between the Appellant and the loanee. 13. That it advanced a loan of Kshs. 20,000,000 to Waridi Paradise Ltd pursuant to a loan agreement dated 22 March 2023 that the said loan was advanced to enable the loanee settle tax arrears arising from an Agency Notice issued by the Respondent 14. The Appellant stated that the funds were not remitted directly to the loanee but were paid to the Respondent pursuant to an agreement between the parties to facilitate lifting of the Agency Notice, as supported by bank statements and the loan agreement. 15. The Appellant stated that the Respondent’s reliance on Section 7(1)(b)(iv) of the Income Tax Act to classify the transaction as deemed dividend was erroneous since the loan remained repayable and was subject to an unconditional undertaking to repay under the loan agreement. 16. The Appellant stated that the loan was duly acknowledged and recorded in its books as receivables under related parties as reflected in its 2023 audited financial statements. 17. The Appellant stated that it advanced a further loan of Kshs. 13,110,651 to the same related party to support working capital due to financial challenges arising from Covid-19 disruptions in 2020 and 2021. 18. The Appellant stated that the additional loan was advanced through settlement of expenses or disbursement of funds in tranches to the loanee. 19. That both loan agreements provided for an interest rate of fifteen percent per annum and included detailed workings of interest amounts. 20. The Appellant stated that it received interest income of Kshs. 654,886 on the loan and remitted withholding tax of Kshs. 98,233 to the Respondent as evidenced by the withholding tax certificate 21. The Appellant stated that it granted the loanee a moratorium on repayment of principal and interest from April 2023 due to adverse economic conditions, as evidenced by correspondence. 22. That the Respondent further erred by charging withholding tax on deemed dividend amounts which had already been or would be subjected to withholding tax on interest, resulting in double taxation. 23. The Appellant stated that it had already accounted for and remitted withholding tax on interest income arising from the loan as referenced earlier. 24. The Appellant stated that treating the loan as deemed dividends despite a binding contractual arrangement would interfere with its legal obligations and distort the nature of the transaction. 25. The Appellant stated that the Respondent’s position would adversely affect both the Appellant and the loanee, jeopardize their operations, and ultimately reduce future tax revenues payable to the Respondent. 26. The Appellant submitted that despite being duly served, the Respondent has not filed any pleadings in the proceedings. 27. The Appellant submitted that it is liable to pay various taxes including Corporation Tax, Value Added Tax (VAT), Withholding Tax (WHT) and Pay As You Earn (PAYE). That in 2023 it executed loan agreements to advance loan facilities of Kshs. 20,000,000 and Kshs. 13,110,651 to a related party, Waridi Paradise Limited. 28. The Appellant submitted that the purpose of the Kshs. 20,000,000 loan was to enable Waridi Paradise Limited to settle a tax liability owed to the Respondent, while the Kshs. 13,110,651 loan was for financing operational expenses. 29. The Appellant submitted that it conceded to certain assessments and entered into a payment plan which it has honoured in accordance with the agreed terms. 30. The Appellant submitted that the Respondent issued an assessment demanding Kshs. 2,308,088 as principal, penalties and interest on alleged deemed dividends arising from the loan advanced to the related party. 31. The Appellant submitted that the issues for determination include whether the loan facility ought to be deemed a dividend, whether the Respondent misapprehended Section 7(1)(b)(iv) of the Income Tax Act (Cap 470), and whether the Appellant is entitled to the reliefs sought, and who should bear the costs. 32. The Appellant submitted that the flow of funds between itself and Waridi Paradise Limited must be interpreted based on the contractual loan agreements and that disregarding these agreements to treat the transaction as a dividend would be legally untenable. 33. The Appellant submitted that it entered into loan agreements advancing Kshs. 20,000,000 and Kshs. 13,110,651 at a commercial interest rate of 15% as evidenced in the agreements annexed to its Statement of Facts. 34. The Appellant submitted that the agreements expressly define the relationship as that of lender and borrower, thereby confirming the existence of a debt obligation and rebutting any presumption of a deemed dividend. 35. The Appellant submitted that the purpose of the loans was to formalize a creditor-debtor relationship and provide liquidity to enable Waridi Paradise Limited settle tax liabilities and maintain business continuity following enforcement action by the Respondent. 36. The Appellant submitted that the loan cannot be construed as a distribution of value since it represents a downward flow of funds from the Appellant to its associate, which is inconsistent with the nature of dividends. 37. The Appellant submitted that a dividend, as defined in Black’s Law Dictionary (9th Edition), is a distribution of profits to shareholders and logically flows from a company to its owners. 38. The Appellant submitted that under Section 2(1) of the Income Tax Act (Cap 470), a dividend is defined as a distribution made by a company to its shareholders with respect to their equity interest. 39. The Appellant submitted that dividends are reserved for shareholders and that by virtue of Section 108 of the Companies Act (Cap 486), a subsidiary cannot be a member of its holding company and therefore cannot receive dividends from it. 40. The Appellant submitted that an associated company such as Waridi Paradise Limited cannot legally receive dividends from the Appellant and therefore no deemed dividend can arise where there is no legal capacity to hold shares. 41. The Appellant submitted that the loan facility is evidenced by contractual formalization, proper execution, commercial interest terms, corporate authorization, structured repayment framework, and recognition as a receivable in audited financial statements. 1. The Appellant submitted that it has demonstrated performance under the loan agreement through receipt of an instalment of Kshs. 654,886 and remittance of WHT of Kshs. 98,233, thereby confirming the existence of a valid loan. 2. The Appellant submitted that the Respondent’s acceptance of WHT on interest is inconsistent with its attempt to re-characterise the same transaction as a dividend. 3. The Appellant submitted that the Objection Decision is flawed and contrary to constitutional principles of fairness, proportionality and equity in taxation. 4. That the Respondent’s position is based on the erroneous assumption that Waridi Paradise Limited is a shareholder, contrary to Section 108 of the Companies Act (Cap 486). 5. The Appellant submitted that an assessment based on a legally impossible relationship is arbitrary and should be set aside. 6. The Appellant submitted that the loan facility is commercial in nature as evidenced by the agreements, interest rate, and WHT remittances, and cannot be treated as a dividend. 7. The Appellant submitted that the Respondent misapplied Section 7(1)(b)(iv) of the Income Tax Act (Cap 470) by treating a loan as a dividend. 8. The Appellant submitted that the Respondent’s interpretation improperly converts a capital intervention into a dividend, contrary to legal and commercial principles. 9. The Appellant submitted that the Respondent’s own findings acknowledge the existence of a loan, the purpose of the funds as settling liabilities and salaries, and their recording in a loan ledger, thereby contradicting the classification as a dividend. 10. The Appellant submitted that treating the loan as a dividend would result in double taxation by imposing 5% WHT on dividends and 15% WHT on interest without justification. 11. The Appellant submitted that it has provided evidence of WHT remittance on interest and that the Respondent’s acceptance of such tax confirms the validity of the loan arrangement. 12. The Appellant submitted that the Respondent’s position that common shareholding converts a loan into a dividend is legally erroneous and commercially disruptive. 13. The Appellant submitted that the High Court in ***Commissioner of Domestic Taxes vs. Dominion Petroleum Kenya Limited (Tax Appeal No. E093 of 2020) [2021] KEHC 283 (KLR)***, as affirmed in ***Commissioner of Domestic Taxes vs. Socabelec East Africa Limited [2024] KEHC 3319 (KLR)****,* held that the presence of interest in a financing agreement confirms the existence of a loan for tax purposes. 14. The Appellant submitted that the stipulated interest rate of 15% and remittance of WHT confirm the transaction as a commercial loan rather than a dividend. 15. The Appellant submitted that common shareholding does not convert a loan into a distribution and that the transaction should be treated as a debt obligation notwithstanding the relationship between the parties. 16. The Appellant submitted that the characterization of the loan must be based on intent and accounting treatment, and that the loan continues to be recorded as an asset despite repayment moratoria. 17. The Appellant submitted that the loan was intended as a strategic intervention to preserve the value of its investment and ensure the business continuity of Waridi Paradise Limited. 18. The Appellant submitted that applying the deemed dividend provision in these circumstances ignores the commercial substance of the transaction and judicial guidance on inter-company financing. 19. The Appellant submitted that treating the transaction as a loan allows the Respondent to collect 15% WHT on interest, which is higher than the 5% applicable on dividends. 20. The Appellant submitted that under Section 56(1) of the Tax Procedures Act, the burden of proof lies on the taxpayer to show that the tax decision is incorrect. 21. The Appellant submitted that it has discharged this burden by providing sufficient evidence to support its case and justify the reliefs sought. 22. The Appellant submitted that under Section 27 of the Civil Procedure Act, costs follow the event and should be awarded to the successful party. 23. The Appellant submitted that having proved its case on a balance of probabilities, it is entitled to costs of the Appeal. # The Appellant’s Prayers 1. The Appellant Prayed 2. The Objection Decision dated 10 September 2025 demanding payment of principal tax of Kshs. 2,308,088 be set aside. 1. The Appeal be allowed with costs to the Respondent. c) Any other orders the Tribunal may deem fit. # THE RESPONDENT’S CASE 1. In response to the appeal, the Respondent filed its Statement of facts dated 26th March, 2025 and filed 31st March 2026 and written submissions dated 30th March 2026 and filed on 31st March 2026. 2. The Respondent stated that the Appellant was issued with notices on 9th April 2025 and additional assessments on 18th June 2025 that upon review of documents, it was established that the Appellant did not remit withholding tax on the deemed dividend arising from the loan extended to Waridi Paradise Limited as required under Section 7(1)(b)(iv) of the Income Tax Act. 3. The Respondent stated that no evidence provided to demonstrate that deemed dividends would not arise from the loans extended to Waridi Paradise Limited as reflected in the loan ledger. 4. The Respondent stated that the Appellant failed to object in accordance with Section 51(2), (3) and (7) of the Tax Procedures Act, which requires a taxpayer to lodge a valid objection within thirty days, specify grounds of objection, pay undisputed taxes or seek extension, and submit all relevant documents. 5. The Respondent stated that the Appellant bears the duty of demonstrating which aspects of the Respondent’s analysis do not reflect the correct tax position. 6. The Respondent stated that it relied on Section 31(4) of the Tax Procedures Act which empowers the Commissioner to amend an assessment in cases of gross or willful neglect, evasion or fraud. 7. The Respondent stated that it is further empowered by Section 31(1)(b) and Section 29 of the Tax Procedures Act to amend assessments based on available information and to the best of its judgment. 8. The Respondent stated that pursuant to Section 24(2) of the Tax Procedures Act, it is permitted to assess a taxpayer’s liability using any information available and therefore acted within the law based on data obtained from the return review. 9. The Respondent stated that Section 51(3) of the Tax Procedures Act outlines the requirements for a valid objection including clear grounds, payment of undisputed tax, and submission of all relevant documents. 10. The Respondent stated that the Appellant’s objection was rejected pursuant to Section 51(3) of the Tax Procedures Act due to failure to provide all relevant supporting documentation. 11. The Respondent stated that its actions were guided by the relevant statutory provisions and aligned with Article 57 of the Constitution of Kenya. 12. The Respondent stated that the Appellant failed to comply with Section 51(3) of the Tax Procedures Act, leaving it with no option but to reject the objection. 13. The Respondent stated that there is no evidence to show that it failed to review documents submitted nor that the Appellant provided sufficient supporting evidence. 14. The Respondent stated that under Section 56(1) of the Tax Procedures Act, the burden lies on the taxpayer to prove that a tax decision is incorrect. 15. The Respondent stated that it reserves the right to adduce further oral and/or documentary evidence at the hearing in support of its position. 16. The Respondent stated that all its actions were undertaken in accordance with Section 51 of the Tax Procedures Act, Section 17(3) and Section 43 of the VAT Act, and Sections 24, 29 and 31(1) of the Tax Procedures Act. 17. The Respondent stated that the Appellant was afforded an opportunity to respond to audit findings and object to the assessment in line with due process. 18. The Respondent stated that the tax assessment issued was properly founded in fact and law and that the objection decision was fair, reasonable and compliant with statutory provisions. 19. The Respondent submitted that the issues for determination are whether the additional assessments were justified and whether the Objection Decision was proper. 20. The Respondent submitted that it is not bound by the Appellant’s tax returns and may assess a taxpayer’s liability using any available information pursuant to Section 24(2) of the Tax Procedures Act, 2015. 21. The Respondent submitted that it is empowered under Section 31 of the Tax Procedures Act to amend assessments based on available information and to the best of its judgment to ensure the correct amount of tax is assessed. 22. The Respondent submitted that it relied on its best judgment and available information in compliance with Section 31 of the Tax Procedures Act when raising the Income Tax assessments, 23. The Respondent submitted that the Appellant’s failure to address discrepancies identified during the audit led to the issuance of additional assessments. 1. The Respondent submitted that the Appellant failed to object in accordance with Section 51(2), (3) and (7) of the Tax Procedures Act which sets out the requirements for lodging a valid objection. 2. The Respondent submitted that as a result of the Appellant’s non-compliance, the objection was rejected on 10th September 2025. 3. The Respondent submitted that the Appellant bears the duty to demonstrate which aspects of the Respondent’s analysis are incorrect and do not reflect the true tax position. 4. The Respondent submitted that the objection was rejected because the Appellant failed to provide sufficient supporting documentation to substantiate the grounds raised. 5. The Respondent submitted that in ***Mulherin vs Commissioner of Taxation [2013] FCAFC 115***, the court held that the burden of proof lies on the taxpayer to demonstrate that an assessment is excessive through positive evidence. 6. The Respondent submitted that the Tribunal in ***Intime Stone Age Limited v Commissioner of Domestic Taxes (Appeal 714 of 2022) [2024] KETAT 44 (KLR)*** emphasized the requirement for taxpayers to provide relevant and specific documentation to support objections. 7. The Respondent submitted that it requested the Appellant to provide specific documents for review. 8. The Respondent submitted that the Appellant failed to provide sufficient documentation to explain the variances identified in the assessments. 9. The Respondent submitted that it was justified in rejecting the objection, as the Commissioner is empowered under Section 59 of the Tax Procedures Act to request additional information. 10. The Respondent submitted that the Appellant has a statutory obligation to maintain records for five years under Section 23 of the Tax Procedures Act. 11. The Respondent submitted that Section 23 of the Tax Procedures Act requires taxpayers to maintain and retain documents to enable accurate determination of tax liability. 12. The Respondent submitted that a reading of Sections 23 and 59 of the Tax Procedures Act demonstrates the Appellant’s obligation to keep and produce records when requested by the Commissioner. 13. The Respondent submitted that where a taxpayer objects to an assessment, it must provide all relevant documentation pursuant to Section 51(3) of the Tax Procedures Act. 14. The Respondent submitted that courts have upheld the requirements of Section 51(3)(c) of the Tax Procedures Act where failure to provide documents rendered the objection invalid. 15. The Respondent submitted that it made follow-up communications requesting the Appellant to provide documentation in support of its objection. 16. The Respondent submitted that Section 56(1) of the Tax Procedures Act places the burden of proof on the taxpayer to demonstrate that a tax decision is incorrect. 17. The Respondent submitted that Section 30 of the Tax Appeals Tribunal Act requires the Appellant to prove that the assessment is excessive or that the decision should not have been made. 18. The Respondent submitted that the Appellant failed to discharge its burden of proof under Section 56(1) of the Tax Procedures Act and Section 30 of the Tax Appeals Tribunal Act. 19. The Respondent submitted that due to the Appellant’s failure to provide proper documentation, it was justified in rejecting the objection in full. 20. The Respondent submitted that the Appellant cannot allege that the Respondent disregarded documents that were never provided. 21. The Respondent submitted that the tax assessment issued was properly founded in fact and law and that the Objection Decision was fair, reasonable, and compliant with statutory provisions. 22. The Respondent submitted that it prays for dismissal of the Appeal, upholding of the tax assessment as confirmed in the Objection Decision, and an award of costs against the Appellant. # The Respondent’s prayers 1. The Respondent prayed that: 2. Dismisses the appeal in its entirety, 3. Upholds the tax assessment as confirmed by the objection decision, and 4. Orders the Appellant to pay the costs of the appeal. # ISSUES FOR DETERMINATION 1. The Tribunal having considered the parties’ pleadings and submissions, puts forth the following issues for determination: # Whether the Tribunal has jurisdiction to entertain the appeal * 1. **Whether the Respondent correctly treated the loan advanced by the Appellant as a deemed dividend subject to Withholding Tax.** **ANALYSIS AND FINDINGS** 1. Having identified the issues for determination, the Tribunal proceeds to analyse the same as hereunder; # Whether the Tribunal has jurisdiction to entertain the appeal 1. The Tribunal has reviewed the context of the dispute that arose from the Respondent’s review of the Appellant’s VAT returns for May and June 2024, following which additional assessments raised disallowing input VAT on the basis of alleged non-compliance and lack of supporting documentation. 2. The Appellant, maintained that it had duly filed its returns and supported its input tax claims with valid invoices, delivery notes, and proof of payment. 3. The Respondent subsequently issued an Objection Decision on 18th July 2025 upholding the assessments, citing failure by the Appellant to provide sufficient documentation within the prescribed timelines, despite being granted an opportunity, including on 30th May 2024, to submit supporting evidence. 4. Against this background, the Tribunal is called upon to determine whether the Appellant’s objection met the statutory requirements under Section 51(3) of the Tax Procedures Act, 2015 (TPA), particularly in relation to the submission of all relevant supporting documents, and consequently whether the Respondent was justified in rejecting the objection and confirming the assessments. 5. The Respondent's position throughout its pleadings and submissions was that the Appellant failed to comply with **Section 51(3)(c) of the Tax Procedures Act** by allegedly failing to provide all relevant supporting documentation and that, as a consequence, the objection was invalid and liable to rejection. 1. Section 51(3)(c) of the Tax Procedures Act provides that a notice of objection shall be treated as valid only if the taxpayer has submitted all relevant documents relating to the objection. Where the Commissioner finds that this requirement has not been met, the legal consequence is not the determination of the objection on its merits; but rather whether the objection is liable to be treated as invalid. 2. The Respondent simultaneously contended that the objection was invalid for want of documentation and yet proceed to render what it styled as an "Objection Decision" dated 10th September 2025, which was purely a rejection of the Appellant’s objection for alleged procedural non-compliance clothed in the language of a substantive Objection decision. 3. If indeed the objection failed to satisfy Section 51(3)(c), there was, in law, no valid objection upon which the Commissioner could exercise the statutory mandate of making an Objection decision as it remains a rejection of the objection. An Objection decision presupposes the existence of a valid objection that has been considered and determined. The Respondent's own case is that the objection was not validly lodged because the Appellant failed to furnish sufficient documents but still went ahead to crown a rejection of objection as an Objection decision. 4. In ***Tax Appeal No. 1282 of 2022 [2024] KETAT 44 (KLR)*** The Tribunal held that: *"The failure to comply with the provisions of Section 51(3) of the Tax Procedures Act renders the notice of objection invalid."* After finding that the taxpayer had failed to submit all relevant documents as required under Section 51(3)(c), the Tribunal stated: *"Consequently, the Tribunal finds and hold that the Appellant's notice of objection was not validated by the Appellant in accordance with Section 51(3)(c) of the Tax Procedures Act."* *"Consequently, the Tribunal having established that the notice of objection is invalid under Section 51(3)(c) of the Tax Procedures Act, it did not delve into other issue."* 1. Further in ***Boleyn International Ltd v Commissioner of Investigations and Enforcement, TAT Appeal No. 55 of 2018***; The Tribunal found that the taxpayer neither provided adequate grounds of objection nor the relevant supporting documents required under Section 51(3)(c). The Tribunal observed; *"Neither did the Appellant provide the relevant documents in support of its alleged objection. Therefore, there was no conceivable way the Respondent would have considered the Appellant's objection as the same did not place itself within the parameters of Section 51(3) of the Tax Procedures Act, 2015."* 1. Finally in ***Skylink Oil Limited v Commissioner of Investigations and Enforcement, TAT No. 302 of 2020,*** The Respondent argued, and the Tribunal considered, that: *"An Objection Decision only arises from a valid Objection and the Appellant's* *Objection being invalid, the Tribunal does not have the jurisdiction to set aside the assessment under review."* 1. The significance of this authority is the principle that a valid objection is a jurisdictional prerequisite to the objection decision process and the subsequent appeal process. Having established that the Tribunal does not have jurisdiction to determine the Appeal, the Appeal is hereby ripe for striking out. 2. Considering the foregoing findings, analysis is of the remaining issue is rendered moot. # FINAL DECISION 1. The upshot to the foregoing is that the Tribunal finds and holds that the Appeal is incompetent and makes the following Orders: 2. The Appeal be and is hereby Struck out. 3. Each party to bear its own cost. 4. It is so Ordered. # DATED AND DELIVERED AT NAIROBI ON THIS 12TH DAY OF JUNE 2026. **.** SIGNED BY/FOR: **★ TH E JUDICIAR Y O F KENY A ★** **HON. ROBERT MUGAMBI MUTUMA (CHAIRPERSON) HON. EUNICE NJERI NGANGA HON. BONIFACE KIBIY TERER HON. BILLY GRAHAM OKUMU MIJUNGU** Tax Appeals Tribunal Tribunal Date: 2026-06-12 13:28:15