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Koriyo Horse Investment Limited v Commissioner of Legal Services and Board Coordination (Tax Appeal E188 of 2025) [2025] KETAT 343 (KLR) (27 October 2025) (Judgment)

[2025] KETAT 343 (KLR) Tax Appeals Tribunal
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Court
Tax Appeals Tribunal
Case number
343
Citation
[2025] KETAT 343 (KLR)
Decided
27 October 2025
AI Summary Beta Machine-generated — may contain errors. Not legal advice.
TypeTax AppealPostureAppeal from an objection decisionCoramM Makau, A Diriye, M Sichahe, B K Terer, S S Oloolchike
Holding

The Appellant’s appeal is dismissed.

Facts

The Appellant, Koriyo Horse Investment Limited, was assessed additional taxes by the Respondent, Commissioner of Legal Services and Board Coordination, for the years 2020-2022. The Appellant filed objections and the Respondent issued an objection decision upholding the assessments.

Issues

  1. Whether the Respondent was statutorily justified to apply a mark-up/cost-plus method in making the assessment.
  2. Whether the Appellant discharged its burden of proving incorrectness of Respondent’s assessments.

Reasoning

The Appellant failed to provide sufficient documentary support for its objections and the Respondent’s assessment was based on available information.

Outcome

Appeal dismissed

Orders

  • The Objection Decision dated 12th November, 2024 be set aside in its entirety.
  • The Tribunal directs the Respondent to reassess the Appellant’s taxable income on actual cost of sales figures and verifiable data.

Authorities cited

Legislation (2)
  • Tax Procedures Act (TPA)
  • Income Tax Act (ITA)
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.
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