The Appeal allowed in part as relates to the imposed penalty under Section 84(1)(a) of TPA, that is not payable at all. The objection decision issued on the 20th September, 2021 for the
principal sum of Kshsl3,370,199.00 plus interest, be and partly upheld.The Appellant was entitled to a tax credit of a sum of Kshs 1,024,838.00 arising from the undisputed taxes subsequently paid on its part. Each party to bear its own costs.
