Same Court, Divergent Approaches: A Pivotal Moment in Taxpayer

This alert brings to your attention two recent decisions, by the High Court in the case of Commissioner of Investigation & Enforcement v Hanqing Zhao (Income Tax Appeal E010 of 2025) [2025] KEHC 16297 (KLR) (Commercial and Tax) (27 October 2025) and Imara Steel Mills Ltd v Commissioner of Investigations & Enforcement (Income Tax Appeal No. E140 of 2024) [2025] KEHC 15394 (KLR).

Both cases interpret Section 51(11) of the Tax Procedures Act (TPA) regarding timelines for Objection Decisions and related compliance obligations.

We have summarised both cases, the high court’s findings, and our opinion below.

Same Court, Divergent Approaches: A Pivotal Moment in Taxpayer–Tax Authority Objection Communication

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Clive Akora

Partner, Tax & Regulatory Services

KPMG in Kenya

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