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OSEJI, J.C.A. (Delivering the Leading Judgment): This appeal is against the judgment of the Federal High Court, Lagos Division delivered by Abdulahi Mustapha CJ. On the 4th day of February 2008, the said court having sat in its appellate jurisdiction over the decision of the Body of Appeal Commissioners. The Body of Appeal Commissioners had in its decision given on 24th November 2006 dismissed the appeal brought before it by the appellant.
The facts of the transaction that led to the dispute which gave rise to this appeal was that by two notices of assessment dated 29-8-2005 (Assessment Notice Nos.: IID/BA/AS/188 and IDD/CT/BT/Add/189) issued by the respondent. The appellant was assessed to tax in the sum of N172,416,369.00 and N23,279,331.00 respectively as tax for the 2004 year of assessment.
The assessment for the sum of N172,416,369.00 is an additional assessment on the appellant and is based on the respondent’s finding that the appellant is not solely engaged in the manufacture of …