A Tax Compliance Certificate does not Create a Legitimate Expectation

"…. the issuance of a tax exemption Certificate was not a ground for estopping the Respondent from executing his mandate as he did in conducting further audits on the taxpayer.

There is considerable case law on this as submitted by the Respondent all of which assert this view. The Tribunal is also of the view that by issuing a tax compliance certificate to the Appellant, the Respondent did not make any legal promise, or representation to the Appellant that it would not enforce the taxes set out in Part 1& 2 of the first schedule to the KRA Act cap 469, laws of Kenya which undertaking could in any event not have had the backing of the law.”