JUDGEMENT
ASIEDU, J.
This appeal stems from an audit undertaken by the respondent herein into the tax returns of the appellant herein for the accounting period of 2014, 2015 and 2016.
After the said audit exercise, the respondent assessed the tax liability of the appellant at an amount of GH₵1, 689,149.34 and thereafter, requested the appellant to pay the said tax liability within a period of thirty (30) days.
After notification of the tax liability, the appellant objected to the assessment and after further examination by the respondent, the liability was reviewed to an amount of GH₵1,085,392.36 after the appellant had brought to the notice of the respondent evidence of new tax credit payments claimed and also taking into consideration the payment of an amount of GH₵506,744.80 after notification of the tax liability.
The Notice of Appeal, which was filed on the 8th January 2018, is brought upon, basically, three main grounds which are that:
a. The finding of CGRA that royalty payments made…