Failure to Object to an Assessment Within Time Allows the KRA to Issue an Agency Notice.

The Tribunal held that the KRA was well within its rights in instituting the agency notices because the debt crystallized upon the Appellant's 30 day period provided by law to file an appeal ending. But the courts found that section 18 of the Tax Appeals Tribunal Act requires it to use its discretion to maintain the validity of the appeal proceedings it was hearing.

The Court determined that it was necessary to temporarily halt the enforcement of the Agency Notices albeit conditionally.