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The Respondent in its final written address formulated the following issues for determination, viz:
a. 'Whether the Respondent was right, when it assessed the Appellant to excess dividend tax (EDT) in accordance with Section 19 of the Companies Income Tax Act?
b. Whether by the rules of interpretation of statutes, the Respondent has erred in law, in its application of Section 19 of the Companies Income Tax Act?
c. Whether any provision of the Respondent's information circular 2012/01 can override the clear provisions of the law?
d. Whether the Respondent indeed varied its position on the Appellant's VAIDS status?