Legitimate Expectation . By issuing the first tax decision the KRA created a legitimate expectation that the matter was fully audited and settled. The KRA cannot audit the same tax period twice for the same matter.

The KRA issued a tax decision based on an audit it undertook, it then reopened the matter the Tribunal held that there must have been sufficient documentation provided by the Appellant and reviewed by the KRA in arriving at the decision and in closing the matter by issuing the first tax decision the KRA created a legitimate expectation that the matter was fully audited and settled. The KRA cannot audit the same tax period twice for the same matter.