JUDGMENT
OSEI, JA.
The undisputed facts of this appeal are that: MULTICHOICE GHANA LIMITED [Plaintiff/Respondent hereinafter referred to simply as Plaintiff] is a Television Company operating in Ghana. It serves its customers in return for their subscriptions which subscriptions the Company saves in a banking account and, as expected earns interest income thereon. From the year 1994 to 1999, the company, without dispute, incurred losses from its Television business as such but made substantial gains from its Banking Account by way of interest. The plaintiff company [Multichoice Ghana Ltd.] then sought to set off its losses incurred from its Television business as such against the interest income earned from the Banking Account. The [Defendant/Appellant] the [Commissioner] [hereinafter referred to simply as Defendant] disallowed that move as illegal and insisted that the income derived from the television business, and the interest accruing to the Bank Account should be taxed separately …