Virginia Wangari v KRA
TAT2026
M-Pesa and bank credits assessed as taxable income where not characterised with contemporaneous documentation.
→ ATT check: CIT-006 — Unexplained bank and M-Pesa receipts
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Each case is structured as: facts, issue, holding, rationale, and checklist implications.
M-Pesa and bank credits assessed as taxable income where not characterised with contemporaneous documentation.
KES 6.8B TP assessment defeated — taxpayer won because documentation was contemporaneous and specific to the entity's actual functions, assets, and risks.
Input VAT disallowed where supplier could not be verified — even where goods were delivered. Buyer's good faith is not a defence.
Appeal struck out for filing 16 days late. Article 159(2)(d) does not cure a missed statutory deadline.
KES 241M TP dispute — TNMM validated; IQR range upheld as arm's length.
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