Section 43 of the Tax Procedures Act

The purpose of section 43 of the TPA is to allow KRA to preserve a tax payers money in the hands of a 3rd party without notice to the tax payer for a limited period before moving the court for formal orders of preservation. Since the exercise of the power to collect taxes, in the manner outlined by the statute, is a justifiable limitation on the right to privacy protected by Article 31 of the Constitution, it must be construed strictly. This approach is buttressed by and consistent with the principle that tax statutes must be interpreted strictly.