<p><strong>SAMUEL CHUKWUDUMEBI OSEJI, JCA(Delivering the Leading Judgment):</strong> This appeal is against the Ruling of the High Court of Justice, Edo State sitting in Benin and delivered on the 21st day of July, 2015, wherein upon an application ex-parte by the Respondent the said Court granted an order of distrain against the properties of the Appellant and in favour of the Respondent based on the claim that the Appellant was liable to pay to the Respondent, the total sum of ₦42,184,790.16k being outstanding arrears on withholding tax on interest accrued therefrom.</p><p>The facts of the case as can be gleaned from the record is that the Appellant which is a commercial bank and carries on business in Nigeria including Edo State received a Demand Notice from the Respondent requesting the Appellant to pay the total sum of ₦122,093,955.14 as withholding tax on interest for the period 2007 to 2012.</p><p>The Appellant then engaged the services of a tax consultant who upon a review, found the amount demanded as unaccep…</p>