<p><strong>OLLENNU, J.</strong></p><p>This matter came before the court under section 58 of the Income Tax Ordinance No. 27/1943 by way of appeal against assessment for the years 1954-55 to 1959-60 raised by the Commissioner of Income Tax in respect of certain payments made to the appellants by the Bremang Gold Dredging Company Ltd., the commissioner having refused upon application of the appellants to amend the said assessments.</p><p>The payments in question were made to the appellants in pursuance of an agreement contained in clause 3B of a deed of assignment between the appellants as vendors and the said Bremang Gold Dredging Company Ltd. as purchasers. The said deed is exhibited to the notice of appeal as exhibit WSD. The reason the commissioner gave for his refund to amend the assessments on the said payments is that the payments were Ghana income (being income derived from land situate in Ghana), and were therefore subject to Ghana tax.</p><p>Proceedings in income tax appeals brought under section 58 of the Income Tax…</p>