The Taxpayer has an obligation to pay the tax not in dispute or enter into an arrangement with the KRA to pay the same before lodging an Appeal

"The Appellant had the obligation to pay the tax not in dispute or enter into an arrangement with the Respondent to pay the same. In the absence of which the Appellant has failed to demonstrate compliance with Section 52 (2) of the Tax Procedures Act hence failing to properly invoke the mandate of the Tribunal as envisaged by the TPA."