https://new.kenyalaw.org/akn/ke/judgment/ketat/2026/321

REPUBLIC OF KENYA IN THE TAX APPEALS TRIBUNAL AT NAIROBI TAT APPEAL NO E1489 OF 2025 URGENT CARGO LOGISTICS LIMITED...........................................….... ……APPELLANT -VS- COMMISSIONER FOR CUSTOMS & BORDER CONTROL......................RESPONDENT JUDGMENT BACKGROUND 1. The Appellant is a private limited company registered in Kenya and dealing in wide range of logistics integrated services including clearing and forwarding services. 2. The Respondent is the principal officer appointed under Section 13 of the Kenya Revenue Authority Act. The Kenya Revenue Authority is an agency of the Government of Kenya mandated with the duty of collection and receipting of all tax revenue, and the administration and enforcement of all tax laws set out in parts 1 & 2 of the First Schedule to the Act, including assessing, collecting, and accounting for all tax revenues in accordance with those laws. 3. The Appellant procured various Customs Security Bonds (“Bonds”) as security for taxes payable to the Respondent in compliance with Sections 106 and 107 of the East African Community Customs Judgment TAT No. E1489 of 2025 – Urgent Cargo Logistics Ltd -vs- Commissioner for Customs & Border Control Page 1 of 20 Management Act, 2004 (EACCMA) through the Respondent’s Simba platform. 4. On 9th April 2024, the Respondent wrote to the Appellant informing them of outstanding bonds in the Simba system and demanding for Kshs. 23,443,101.00 5. On 15th May 2024, the Appellant wrote to the Respondent requesting to be facilitated with the accounting and subsequent cancellation of bonds listed in the letter. 6. On 16th May 2o24, the Respondent responded demanding for taxes amounting to Kshs. 16,826,499.00 inclusive of penalties and interests. The parties then engaged in various correspondences in an attempt to reconcile the matter. 7. On 29th August 2024, the Respondent issued its final demand on the Appellant’s appeal on interest and penalty on the late cancellation on the transit bonds and demanding Kshs. 19 million from the Appellant. 8. Aggrieved by the Respondent’s demand, the Appellant file this Appeal vide Notice of Appeal dated 22nd December, 2025 with leave of the Tribunal. THE APPEAL 9. In its Memorandum of Appeal dated 22nd December 2025, the Appellant raised the following grounds of appeal: - a. The Respondent erred in fact and in law in enforcing Security Bonds whose liability had been extinguished upon the lapse of Judgment TAT No. E1489 of 2025 – Urgent Cargo Logistics Ltd -vs- Commissioner for Customs & Border Control Page 2 of 20 one year, contrary to the Respondent’s own established Bond Procedure Guidelines in violation of the Appellant’s right to legitimate expectation. b. The Respondent erred in fact and law in enforcing General Security Bonds whose liability had been extinguished upon the lapse of three years, contrary to the Respondent’s own established Bond Procedure Guidelines in violation of the Appellant’s right to legitimate expectation. c. The Respondent erred in fact and law by auditing the Appellant beyond the statutory period provided in law in breach of Section 235 of the East African Community Customs Management Act, 2004, and in violation of the Appellant’s constitutional right to fair administrative action protected under Article 47 and 232 of the Constitution. d. The Respondent erred in fact and law in failing to provide the Appellant with a statement of reasons for the justification and or computation of how she arrived at the figure of Kshs. 19,000,000 as interest and penalty for late cancellation of bonds in breach of Section 49 of the Tax Procedures Act. e. The Respondent erred in fact and law in demanding interest and penalty for late cancellation of bonds from the Appellant and failed to appreciate that the Appellant was not the owner of the imported/exported goods and neither was the Appellant the surety or the guarantor under the Special Security and General Security Bonds that were issued. Judgment TAT No. E1489 of 2025 – Urgent Cargo Logistics Ltd -vs- Commissioner for Customs & Border Control Page 3 of 20 f. The Respondent erred in law and fact in misapplying Section 145 of the East African Community Customs Management Act, 2004 by construing the Appellant as the owner of the imported/exported goods when the Appellant’s liability as the agent of the importers/exporters ceased once the goods were cleared by the Respondent. g. The Respondent erred in law and fact in shifting liability of the late cancellation of bonds from the Appellant despite the delay having been occasioned by the Respondent when it misplaced the Appellant’s cancellation documents within its offices in breach of the Appellant’s right to fair administrative action. h. The Respondent erred in law and fact by refusing to cancel some of the bonds despite the Appellant submitting all the required documents within the timelines prescribed by the law. i. The Respondent erred in law and fact by failing to appreciate that the cancellation of bonds is a preserve of the Respondent and not the Appellant as long as the Appellant had submitted to the Respondent Form 26 and the certificate of export. j. The Respondent erred in law and fact by demanding an ambiguous tax in breach of clear taxation principles that requires the Respondent to demand tax in clear and unambiguous words. k. The Respondent erred in fact and law by failing to consider the evidence rendered by the Appellant thereby violating the Appellant’s right to fair administrative action protected under Article 47 of the Constitution. Judgment TAT No. E1489 of 2025 – Urgent Cargo Logistics Ltd -vs- Commissioner for Customs & Border Control Page 4 of 20 l. The Respondent misapplied the law and facts, and therefore arrived at the wrong decision. APPELLANT’S CASE 10. The Appellant’s case is based on its Statement of Facts dated 22nd December 2025, and written submissions dated 30th June, 2026. 11. The Appellant averred that it procured bonds as security for taxes payable by its clients who imported and/or exported various goods into/out of Kenya. The Appellant’s clients had imported the goods for various reasons including the goods that were in transit and goods that were for home consumption. However, the following eleven (11) bonds have remained pending on the Simba platform that is maintained by the Respondent: GBNSB4216/05; PCSB04194/08; GCSB0829/09; PCSB00218/09; PCSB02692/09; GCSB11002/14; GCSB02049/14; PCSB05431/14; GCSB05172/16; GCSB00141/17; and RCTG17/03958KE. 12. The Appellant further averred that legitimate expectation was created when the Respondent issued Bond Procedures Guidelines to the effect that General Security Bonds and Particular Security Bonds are valid for periods of three (3) years and one (1) year respectively. 13. The Appellant contended that it legitimately expected upon the lapse of one year the liability of the security bonds extinguished whereas the liability of General Security Bonds upon the lapse of three years. Judgment TAT No. E1489 of 2025 – Urgent Cargo Logistics Ltd -vs- Commissioner for Customs & Border Control Page 5 of 20 14. The Appellant asserted that it a principle of fairness that legitimate expectation ought not to be thwarted and the constitutional principle of the rule of law calls for predictability and certainty in government dealings with the public including by adhering to the statutory provisions. 15. It is the Appellant’s case that the Respondent cannot therefore enforce Security Bonds whose liability had been extinguished upon the lapse of one year and General Security Bonds whose liability had been extinguished upon the lapse of three years contrary to its own Bond Procedures Guidelines. 16. The Appellant stated that the Respondent’s decision of demanding for interest and penalty of Kshs. 19,000,000.00 for late cancellation of the custom bonds is unfair, irrational and unreasonable decision and a violation of the Appellant’s legitimate expectation contrary to Article 47 as well as Fair Administrative Action Act, 2015. 17. The Appellant contended that the Respondent is mandated by Section 235 of the EACCMA, 2004 to request the owner of any goods to produce books, records and documents relating in any way to the goods and to answer any question about the goods that are the subject of EACCMA, 2004 (the audit). It provides that the audit should be conducted within five (5) years of importation, exportation, transfer or manufacture of the goods. 18. It is the Appellant’s case that by dint of Clause 235 of EACCMA, 2004, and the Respondent’s Bond Procedures Guidelines, the period within which the Respondent is mandated to have called for Judgment TAT No. E1489 of 2025 – Urgent Cargo Logistics Ltd -vs- Commissioner for Customs & Border Control Page 6 of 20 documentation was five (5) years from the dates of various bonds expired. 19. The Appellant stated that the Respondent’s first demand to the Appellant for unpaid taxes and/or fines and penalties for late cancellation under the procured Bonds was made in or around October 2019. The time the first demand was made, the following Bonds had expired as well as the audit periods: GBNSB4216/05; PCSB04194/08; GCSB0829/09; PCSB00218/09; PCSB02692/09. However, the first demand only made reference to the following bonds: GCSB05172/16; and GCSB00141/17. 20. The Appellant averred that on 7th September 2022, the Respondent made another demand (the second demand) for the Appellant to account for the goods under the Bond Number GCSB02049/14 and RCTG17/03958KE or pay the Respondent Kshs. 32,358,677.00. 21. The Appellant further averred that Bond Number GCSB02049/14 expired on 18th February 2017 and its audit period had expired on 18th February 2022, five (5) months before the second demand by the Respondent. Thus, the Appellant could not be expected to have the documentation in relation to this Bond Number GCSB02049/14, and had legitimate expectation that the said Bond had already been cleared and cancelled by the Respondent. 22. It is the Appellant’s contention that the net effect is that as of 7th September 2022, only the following bonds had been validly and legally demanded: GCSB05172/16; GCSB00141/17; and RCTG17/03958KE. Judgment TAT No. E1489 of 2025 – Urgent Cargo Logistics Ltd -vs- Commissioner for Customs & Border Control Page 7 of 20 23. The Appellant contended that the process of cancellation or retirement of Bonds is as follows: - a) The importer/exporter or their agent (in this case, the Appellant) submits to the Respondent a rotation request or submits the manifest entry; b) The goods are cleared by the Respondent at the border; c) Where there are any exemptions; or d) The cargo is allowed by the Respondent to cross the border; e) The Respondent issue to the importer/exporter with a certificate of export; f) The importer/exporter fills the Form 26 and attaches the certificate of export; g) The certificate of exit and Form 26 are then lodged with the Bond Section of the Respondent’s office. 24. The Appellant averred that declarations or entries that are subject to the Bonds that have been queried by the Respondent within the law were made by the Appellant between the years 2017 and 2018. 25. The Appellant stated that the goods that are the subject of Bond Numbers GCSB05172/16 and GCSB00141/17 are tax exempt, and the Appellant submitted the entries for this Bond within the stipulated period, but because of the delay by the Respondent in processing the exemptions, the entries were not processed on time leading to the delay in cancellation of the Bond. Under these circumstances, it will be unfair for the Respondent to hold the Appellant liable for the delays that were occasioned by the Respondent itself. Judgment TAT No. E1489 of 2025 – Urgent Cargo Logistics Ltd -vs- Commissioner for Customs & Border Control Page 8 of 20 26. The Appellant stated that upon making the declarations/entries, it had legitimate expectation that the Bonds would be cancelled by the Respondent after the Respondent had processed the exceptions. 27. The Appellant stated that goods under Bond Number RCTG17/03958KE were goods that were in transit. The said goods exited the country within the stipulated period. Following their exit, the Appellant was issued with a hardcopy of the Certificate of Exit by the Respondent. The Appellant lodged the hardcopies of the Certificate of Exit together with Form 26 at the Respondent’s office, but unfortunately, the documents were misplaced by the Respondent’s staff leading to the delay in cancellation of the Bonds. 28. The Appellant submitted that by submitting the hard copies to the Respondent for the cancellation of the Bonds within thirty (30) days of the goods leaving the country, the Appellant had done all within its power and control. Therefore, it would be unjust for the Respondent to demand fines and penalties given that the error was occasioned by its staff. 29. It is the Appellant’s case that the Respondent has refused/neglected to cancel Bond Number RCTG17/03958KE claiming illegitimately for penalties and fines for late cancellation before it can cancel the same. 30. It is the Appellant’s further case that without prejudice to the foregoing, at all material times, the Bonds referred to above were guaranteed by APA Insurance Limited, and the Respondent has not attempted to claim from the underwriter of the risk. Instead, it has gone after the insured contrary to the principles of customs bond. Judgment TAT No. E1489 of 2025 – Urgent Cargo Logistics Ltd -vs- Commissioner for Customs & Border Control Page 9 of 20 31. The Appellant stated that additionally, at all material times, it was an agent of the importers/exporters of the goods that are the subject of fines and penalties, and the Respondent did not attempt to claim from the importers/exporters of the goods who are the principal. 32. It is the Appellant’s assertion that throughout the Bonds in question, there have been no taxes that the Respondent has lost, and neither has there been any tax evasion by the Appellant or any of its clients. All the goods either left the country and certificate of export issued by the Respondent or were tax exempted and cleared by the Respondent. 33. The Appellant asserted that the main aim of customs bond is to secure the payment of taxes when they fall due and not punish taxpayers as the situation in this case. 34. The Appellant further asserted that the late cancellation of Bonds is not the creation of its actions or omission, but that of the Respondent. Therefore, it will be unjust to subject the Appellant to punitive fines and penalties. 35. It is the Appellant’s case that it has insured the risk of penalties and fines for late cancellation, and therefore the Respondent should seek payment of the penalties and the fines from the underwriter, if at all they are payable. 36. The Appellant stated that the Respondent erred by construing the Appellant as the owner of the imported/exported goods under Section 145 EACCMA, 2004 to recover the payable principal tax and Judgment TAT No. E1489 of 2025 – Urgent Cargo Logistics Ltd -vs- Commissioner for Customs & Border Control Page 10 of 20 penalties, yet the Appellant’s liability as the agent of the importers/exporters ceased once the goods were cleared by the Respondent. 37. The Appellant averred that the Respondent did not provide the Appellant with a statement of reasons for the justification and or computation of how it arrived at the figure of Kshs. 19 million as interest and penalty for late cancellation of Bonds in breach of Section 49 of the Tax Procedures Act. 38. According to the Appellant, it is not clear on exact taxes the Respondent is demanding from the Appellant. In its letter dated 29th August 2024, the Respondent is demanding for interest and penalty of Kshs. 19 million, whereas in a letter dated 26th November 2025, the Respondent is demanding for penalty to Bond of Kshs. 9,573,217 for late Bond cancellation, and Kshs. 1,209,223 being penalty to Bond plus interest and penalties. The ambiguity is in breach of clear taxation principles that requires the Respondent to demand tax in clear and unambiguous words. 39. In its written submissions dated 30th June 2026, the Appellant largely reiterated the above contentions, and cited various case law in support of its appeal. APPELLANT’S PRAYERS 40. The Appellant prayed to the Tribunal for the following orders: - a) The Appeal be allowed. b) The Respondent’s decision contained in its letter dated 29th August 2024 demanding for interest and penalty of Kshs. Judgment TAT No. E1489 of 2025 – Urgent Cargo Logistics Ltd -vs- Commissioner for Customs & Border Control Page 11 of 20 19,000,000 for late cancellation of custom bonds be annulled and set aside. c) The Respondent’s letter dated 26th November 2025 demanding for penalty to Bond of Kshs. 9,573,217 for late Bond cancellation and Kshs. 1,209,223 being penalty to Bond plus interest and penalties by annulled and set aside. d) An order compelling the Respondent to cancel all the disputed Special Security and General Security Bonds that have been discharged by the Appellant. e) An order compelling the Respondent to cancel all the Special Security and General Security Bonds that have expired after their three-year term. f) Any other remedies the Honorable Tribunal deems just and reasonable. RESPONDENT’S CASE 41. The Respondent filed its Statement of Facts dated 10th February 2026, and Written Submissions dated 30th June, 2026 in opposition to the Appeal. 42. The Respondent averred that the Appellant, being a customs agent and authorized economic operator, procured bonds as security for taxes in compliance with Section 106 and 107 of the EACCMA, 2004. The bonds were both general and particular security bonds valid for 3 and 1 year respectively. Judgment TAT No. E1489 of 2025 – Urgent Cargo Logistics Ltd -vs- Commissioner for Customs & Border Control Page 12 of 20 43. The Respondent further averred that upon carrying out a reconciliation, it found that there were outstanding transactions in the system and more specifically with regard to the bonds review process, which included the verification of Forms C36 and cancellation and retirement of bonds from the system. 44. The Respondent stated that it noted that the Appellant made a Late Application for Bond Cancellation (Regulations 104(15) – (17) of EACCMR 2010) for entries numbers RCTG17/0395KE and GCSB02049/14. 45. The Respondent pleaded that pursuant to Section 235 of EACCMA, it is required to carry out an audit within 5 years of the importation, exportation, transfer or manufacture of the goods. It demanded unpaid taxes/fine and penalties for late cancellation under the procured bonds when the audit period had expired. 46. The Respondent further stated that the Appellant was requested to confirm whether the goods which were bonded were re-exported by submitting the export entry number and in cases where the goods were converted to home use, evidence of duty payment, but the Appellant was unable to avail the evidence showing re-export for goods or payment of duties, thus the demand for taxes. 47. The Respondent asserted that it relied on Regulation 104 (12) & (13) of EACCMA Regulations 2010, which covers failure to export the transit goods. Judgment TAT No. E1489 of 2025 – Urgent Cargo Logistics Ltd -vs- Commissioner for Customs & Border Control Page 13 of 20 48. The Respondent stated that entry no. 2017MSA 6513737 under bond RCTG17/03958KE has not been proved to have been exported thereby contravening the provision of the above section. 49. It is the Respondent’s case that packages under this entry were concluded to never exported as no evidence of export was availed to the Respondent. The full BIF remains outstanding and is payable along with the relevant interest and penalties. 50. The Respondent asserted that the Appellant failed to account for all packages in a customs entry declaration, whereupon taxes were levied on the subject entry in accordance with the provisions of Regulation 104 (12) and (13). Additionally, the Appellant neglected to file for bond cancellation within the mandatory thirty-day (30) period subsequent to exportation, in contravention of Regulation 104 (16) and (17). It was further noted that the client had other outstanding transactions under different customs regimes recorded in the SIMBA system, which remained unresolved and represent subsisting obligations of the Appellant. 51. The Respondent posited that nothing can extinguish liabilities entered into by a person who have given a bond under Section 108 of EACCMA unless it allows the same under Section 109(2). 52. It is the Respondent’s position that it is at liberty to demand accountability of bonds as per the provisions of Section 109 of EACCMA, and the expiry of the bonds can only be in relation to utilization and not from enforcement and or accounting for the same. The Appellant was the principal and is obligated under Sections 107 Judgment TAT No. E1489 of 2025 – Urgent Cargo Logistics Ltd -vs- Commissioner for Customs & Border Control Page 14 of 20 and 109 EACCMA to ensure performance of the conditions under the bond. 53. The Respondent asserted that the Appellant is also the agent and is obligated by the provisions of Section 147 of EACCMA to pay any duty in respect of goods and perform any acts with regard to the goods, which the owner is supposed to perform. 54. The Respondent averred that it did not misplace the Appellant’s documents as stated and there was no evidence justifying such claims, and the Appellant did not provide any evidence that the documents were submitted earlier. 55. The Respondent stated that if the Appellant had applied in time, the penalties could not have accrued. Regulation 104 (15,16 and 17) demands applications under Form C26 are supposed to be done within 30 days of exportation, failure to which penalties accrue. Further, cancellation of bonds only happens after performance of the obligation entered into by the person giving the security guided under Section 107 (3) and (4) of EACCMA. 56. Finally, the Respondent averred that it properly applied the law and the outcome is a demonstration of that. The Commissioner’s findings are therefore anchored in the law. 57. In its Written Submissions dated 30th June, 2026, the Respondent largely reiterated the above assertions to support its case. RESPONDENT’S PRAYERS 58. The Respondent prayed to the Tribunal for the following orders: - Judgment TAT No. E1489 of 2025 – Urgent Cargo Logistics Ltd -vs- Commissioner for Customs & Border Control Page 15 of 20 a) The Appeal be dismissed with costs to the Respondent. ISSUES FOR DETERMINATION 59. The Tribunal having considered the parties' pleadings, submissions and documents filed before it is of the view that the issue that falls for its determination is whether the Respondent’s Decision dated 29th August 2024 declining waiver of penalty and interests of Kshs. 19 million is justified. ANALYSIS AND DETERMINATION 60. The instant Appeal is predicated on the Appellant’s Notice of Appeal dated 22nd December 2025 appealing the Respondent’s decision of 29th August 2024. The said letter, which is on record, concerns the decision of the Respondent to decline the Appellant’s appeal for waiver on interest and penalty on late cancellation of transit bonds of Kshs. 19 million. 61. The Respondent justified its decision on the ground that the Appellant had not supported its argument that it submitted cancellation requests on time, but the documents were misplaced between offices. The Respondent asserted that there is no record of such documents in the registers of Bonds Management Section. In this regard, the Respondent submitted that it cannot grant waiver under Section 249 of the EACCMA, 2004. 62. On its part, the Appellant submitted that goods under Bond Number RCTG17/03958KE were goods that were in transit. The said goods exited the country within the stipulated period. Following their Judgment TAT No. E1489 of 2025 – Urgent Cargo Logistics Ltd -vs- Commissioner for Customs & Border Control Page 16 of 20 exit, the Appellant was issued with a hardcopy of the Certificate of Exit by the Respondent. The Appellant lodged the hardcopies of the Certificate of Exit together with Form 26 at the Respondent’s office, but unfortunately, the documents were misplaced by the Respondent’s staff leading to the delay in cancellation of the Bonds. 63. The Appellant further submitted that by submitting the hard copies to the Respondent for the cancellation of the Bonds within thirty (30) days of the goods leaving the country, the Appellant had done all within its power and control. Therefore, it would be unjust for the Respondent to demand fines and penalties given that the error was occasioned by its staff. 64. The Tribunal notes that the Appeal, as presently framed, is confined to the narrow issue of whether the Appellant cancellation requests for the bonds was submitted on time or not. It is the alleged late submission of cancellation requests that led to interest and penalty that are the subject of the appeal that the Respondent declined. 65. The Tribunal has painstakingly reviewed all pleadings, correspondences and documents on record. Whilst it is clear that the parties took significant steps to reconcile the issues in dispute, there is no record support the Appellant’s contention that it submitted its application for cancellation on bonds on time. The argument that the documents were misplaced between offices cannot hold in tax disputes, and flies against the very argument of submission was made on time. 66. Section 223 of EACCMA 2004 provides as follows regarding burden of proof in proceedings under the Act: - Judgment TAT No. E1489 of 2025 – Urgent Cargo Logistics Ltd -vs- Commissioner for Customs & Border Control Page 17 of 20 “In any proceedings under this Act— (a) the onus of proving the place of origin of any goods or the payment of the proper duties, or the lawful importation, landing, removal, conveyance, exportation, carriage coast- wise, or transfer, of any goods shall be on the person prosecuted or claiming anything seized under this Act; 67. Section 234 (3) of EACCMA, 2004 also provides as follows regarding production of documents to the Respondent: “Where the proper officer requires any document to be produced for any goods which have been imported, exported, transferred, or declared in transit, the proper officer may require the document to be submitted in original and duplicate and the proper officer may retain the original” 68. Furthermore, Section 30 of the Tax Appeals Tribunal Act (cap 469A) provides as follows on the Appellant’s burden of proof: - In a proceeding before the Tribunal, the appellant has the burden of proving—(a)where an appeal relates to an assessment, that the assessment is excessive; or(b)in any other case, that the tax decision should not have been made or should have been made differently. 69. The Honourable Tribunal has also previously reiterated the Appellant’s duty to discharge its burden of proof in the first instance. In Abyssinia Iron and Steel Ltd -vs- Commissioner of Customs and Border Control (TAT No. 435 of 2022), the Tribunal held as follows: - Judgment TAT No. E1489 of 2025 – Urgent Cargo Logistics Ltd -vs- Commissioner for Customs & Border Control Page 18 of 20 The bottom line is that once the Appellant has provided evidence that the Respondent's assessment was wrong, then the Respondent must push back and show that its assessment was not arbitrary, capricious, or imagined. The onus will then shift back to the Appellant once the Respondent has discharged its burden on a balance of convenience to discharge the prima facie case that has been presented by the Respondent. 70. Having considered the pleadings and records before it, the Tribunal is constrained to find and hold that the Appellant did not sufficiently support its appeal on waiver of interest and penalty on late cancellation of transit goods. The Respondent’s decision dated 29th August 2024 was therefore justified. DISPOSITION 71. The upshot of the foregoing analysis is that the Tribunal find and holds that the Appeal lacks merit and proceeds to issue the following orders: - a. The Appeal be and is hereby dismissed. b. The Respondent’s Decision dated 29th August 2024 be and is hereby upheld. c. Each Party is to bear its own costs. 72. It is so ordered. DATED and DELIVERED at NAIROBI this 21ST Day of August 2026 Judgment TAT No. E1489 of 2025 – Urgent Cargo Logistics Ltd -vs- Commissioner for Customs & Border Control Page 19 of 20 ................................................................ DR. ERICK KOMOLO CHAIRMAN ……………………………. ……..............…………….. ABDULLAHI M. DIRIYE CYNTHIA MAKAYA MEMBER MEMBER Judgment TAT No. E1489 of 2025 – Urgent Cargo Logistics Ltd -vs- Commissioner for Customs & Border Control Page 20 of 20