It is not enough for the Taxpayer to establish that the KRA’s estimations are mistaken or erroneous It is necessary that they go further and establish what their taxable incomes actually are.

"....it is not enough for the applicants to establish that the Respondent’s estimations were mistaken or erroneous in some or even many respects. It is necessary that they go further and establish what their taxable incomes actually were. But the bottom-line question, as it were, will always be: what were the taxable incomes of the applicants? It is for them to determine how they will go about answering that question.”