JUDGMENT OF AGANYANYA, J.A.
This appeal arises from the decision of the superior court (Wendoh, J) dated 23rd November, 2007 dismissing the appellants application for Judicial Review. By the application dated 21st September, 2005 the appellant sought the following orders namely:-
“(a) AN ORDER OF CERTIORARI removing to this Honourable Court for the purpose of the same being quashed the letter dated 2nd September, 2002 written by V.W. Muhatia for the Deputy Commissioner Large Tax Payer Office, Kenya Revenue Authority and addressed to Messrs. KPMG Kenya and the letter dated 8th September, 2005 written by J. M. Ojee Senior Assistant Commissioner, Large Taxpayer office, Kenya Revenue Authority and addressed to the Finance Director, Stanbic Bank Kenya Limited.
(b) AN ORDER OF PROBIHITION to prohibit the Respondent or any of its agents or any other party acting for and on behalf of the Respondent from further demanding from the applicant or its agents the sum of Kshs.7,954,342.00 or any sum at…