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Sirikwa Eldoret Hotel Limited v Commissioner of Domestic Taxes (Tax Appeal 408 of 2019) [2021] KETAT 172 (KLR) (25 June 2021) (Judgment)

[2021] KETAT 172 (KLR) Tax Appeals Tribunal
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Court
Tax Appeals Tribunal
Case number
172
Citation
[2021] KETAT 172 (KLR)
Decided
25 June 2021
AI Summary Beta Machine-generated — may contain errors. Not legal advice.
TypeTax AppealPostureAppeal from a decision of the Commissioner of Domestic TaxesCoramHELEN B1LA MWAI MBUTHIA, ELI SHAH NJERU HABON FARAH
Holding

The Appeal is dismissed.

Facts

The Respondent issued an Agency Notice demanding Kshs. 18,251,615.00 from the Appellant, who had previously been ordered to pay this amount in a High Court case. The Appellant appealed the decision to the Court of Appeal, which upheld the High Court's decision that there was a transfer of tax liability from Hotel Sirikwa Limited to Sirikwa Eldoret Hotel Limited.

Issues

  1. Whether the Tribunal has jurisdiction to hear and determine the matter.
  2. Whether the Respondent is legally justified in demanding the tax liability of Kshs. 18,304,263.00 from the Appellant.

Reasoning

The Tribunal found that the Respondent had jurisdiction to issue the Agency Notice and that the Respondent was legally justified in demanding the tax liability from the Appellant. The Appellant's appeal was dismissed as the High Court had already determined that there was a transfer of tax liability from Hotel Sirikwa Limited to Sirikwa Eldoret Hotel Limited.

Outcome

Appeal dismissed

Orders

  • The Appeal be and is hereby dismissed.
  • Each party to bear its own costs.

Authorities cited

Legislation (3)
  • Income Tax Act
  • Tax Procedures Act
  • Tax Appeals Tribunal Act
Cases cited (3)
  • Kry stall ine Salt Limited versus Kenya Revenue Authority
  • THE INDEPENDENT ELECTORAL AND BOUNDARIES COMMISSION-vs-MAINA K1A1 & 5 OTHERS
  • KENYA HOTEL PROPERTIES LIMITED -vs- ATTORNEY GENERAL & 5 OTHERS
Experimental AI summary generated by a language model, not a lawyer. It may contain errors or omissions and must not be relied on for legal decisions — the full judgment below is the authoritative source.
Full judgment 1.0 MB · PDF

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