QUAYE J. A, DOTSE J. A, SAMPONG J. A.
In the matter of the Internal Revenue Act 2000 (Act 592).
And
In the matter of an appeal against assessment of tax by the commissioner Internal Revenue.
Chapel Hill School Ltd. ---- Appellant
And
Attorney-General ---- 1st Respondent
Commissioner of Internal Revenue ---- 2nd Respondent
This is an appeal from the judgement of Sekondi High Court delivered on 1st February 2006. The facts of this case appear to be simple and they may be summarized before addressing the issues raised in the appeal. The appellant in this case is an institution known as Chapel Hill School Ltd. which was initially called Chapel Hill Preparatory School based in Takoradi and it was established about forty seven years ago. It was ran by a Board of Directors according to its instrument of incorporation and it was a company limited by guarantee in comformity with the requirements of the Companies Code 1963 (Act 179).
In the year 2001, the company transformed itself into a company limite…