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ISSUES FOR DETERMINATION
From the above contentions of the parties, the crux of the appeal before this Tribunal is narrowed down to the issue of payment of penalties and interest on the tax accruable to the respondent. In arguing their respective positions on the matter, the parties raised the following issues for determination;
1) Whether or not the Demand Notice with References No: LA/IRS/B468/DN/14403/06/14 is final and conclusive.
2) Whether interests and penalties are applicable to an assessment which is not final and conclusive.
3) Whether or not the appellant is liable to pay penalties and interest on the Withholding Tax (WHT) and PAYE arising from 2007 2012 years o f assessment.