Tax Audit

Can KRA Challenge Your Old Tax Losses? The Patel Case and the 5-year Limit

Vijay Kumar Shamji Patel v Commissioner For Legal Services & Board Co-Ordination Services. The Tax Appeals Tribunal’s decision in Patel v KRA confirms that KRA is barred from amending tax assessments after five years unless fraud or willful neglect is proven. The case reinforces important taxpayer protections against prolonged audits and retrospective reassessment of historic […]
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High Court Ruling on Missing Traders & Burden of Proof

Commissioner of Domestic Taxes v Dinesh Construction Limited (2025) KEHC 17058 (KLR) Background In 2021, KRA audited Dinesh Construction Limited for the years 2016–2021 and flagged risks in corporation tax, VAT, PAYE and Withholding Tax. KRA issued a confirmed assessment claiming: Missing Traders:  Dinesh claimed VAT inputs from suppliers who were “missing traders” entities that […]
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