FEDERAL INLAND REVENUE SERVIC
V.
CITIBANK (NIG) LTD

EBIOWEI TOBI, J.C.A.(Delivering the Leading Judgment):​The Appellant imposed an additional tax based on assessment for the years 2008-2010 on the Respondent. The Respondent challenged those taxes in the Tax Tribunal. The additional tax was assessed as in relation to the Company Income Tax (CIT) and the Education Tax (EDT) totaling N728,788,304.91. The Tax Tribunal allowed the additional tax assessment. The matter got to the Tax Appeal Tribunal which in its judgment upheld the decision of the Tax Tribunal. In other words, the Tax Appeal Tribunal dismissed the appeal and upheld the decision of the Tax Tribunal. The Respondent did not end there but proceeded to the Federal High Court which has jurisdiction on tax matters. The Respondent appealed to the Federal High Court. The Federal High Court presided over by Hon. Justice M.B. Idris( now of the Court of appeal) upheld the appeal and set aside the judgments of the Tax Tribunal and the Tax Appeal Tribunal. The Appellant dissatisfied with…