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ISSUE FOR DETERMINATION
The Appellant, in its Written Address, formulated one issue for determination, to wit,
“Whether in the circumstances of this case, (Appellant) is liable to interests and penalties’’
Similarly, the Respondent, in its Written Address formulated a single issue for determination as follows,
“Whether based by (sic) the combined effect of Section 32(1) of the FIRS Act, Section 74(1) of the PITA and Paragraph 8 of the Operations of PAYE SchemeRegulation, the Appellant is liable to pay penalty and interest on the tax arising from 2007 to 2012 YOAs; same not having been remitted to the Respondent in the YOAs’’
Looking at the issues formulated by the respective Parties, it becomes clear that they are indeed similar. However, we have reviewed the Addresses of both parties and the arguments canvassed by their respective Counsel, we have therefore come to a conclusion that the question that calls for determination is: -Whether the Appellant should be liable to interests and penalties in the circumstances of this case