Extension of Time for Late Appeal Submission

The Tribunal considered three key factors in evaluating the application for an extension of time.

1. Merits of the Appeal: The Tribunal found that Adnan had identified three grounds in its Memorandum of Appeal, demonstrating that the appeal was arguable.
2. Prejudice to KRA: The Tribunal determined that granting the extension would not prejudice the Kenya Revenue Authority and that the appeal could be heard on its merits.
3. Reason for Delay: The Tribunal was not satisfied with Adnan’s explanation for the delay. It concluded that Adnan had not shown that the delay was due to circumstances beyond its control and deemed the delay inordinate.

Consequently, the Tribunal denied the application for an extension of time.