JUDGMENT OF THE COURT
Kenya Revenue Authority (KRA) (the appellant), which was the 4th respondent in the High court, is a statutory body corporate established under Section 3 of the Kenya Revenue Authority Act, (Cap 469 of the Laws of Kenya), whose core function is to assess, collect and account for all revenues, on behalf of the Government of Kenya.
Doshi Iron Mongers (the1st respondent) on the other hand, is described in the pleadings as a company registered and trading in the Republic of Kenya, dealing in general merchandise. It used to import its merchandise from various countries in the world.
Ashok Doshi (the 2nd respondent), is described as a director of the 1st respondent. According to the respondents, they had carried out the said business for about two decades by the time the petition before the High Court, from which this appeal emanates, was filed.
The respondents’ grievance was that in the period between 1996 and 2004, the appellant together with other state agencies who were…