FEDERAL BOARD OF INLAND REVENUE V. HALLIBURTON (WA) LIMITED

JOSEPH SHAGBAOR IKYEGH, JCA (DELIVERING THE LEADING JUDGMENT): The appeal is from the decision of the Federal High Court Lagos (the court below) which had set aside the judgment of the Body of Appeal Commissioners (the Body) respecting a tax matter decided by the Body in the appellant's favour.

Sketchily, the facts that bear on the appeal indicated that the appellant had made additional assessment of US$6,927,248 (six million, nine hundred and twenty seven thousand, two hundred and forty eight dollars) for the tax years of 1996, 1997, 1998 and 1999 on the respondent which was affirmed by the Body. The respondent appealed to the court below on points of law alone seeking an order of the court below to set aside the judgment of the Body by declaring the said additional assessment invalid, null and void and directing the appellant to refund to the respondent the said sum of US$6,927,248 with interest thereon to be determined by the court below.

The additional assessment arose from contra…