DODOO (MRS), J.
It is provided for in Section 100(1) of the Revenue Administration Act, 2016 as follows:
To achieve consistency in the administration of tax laws and to provide guidance to persons affected by the tax laws, including tax officers, the Commissioner-General may issue practice notes setting out the interpretation placed on provisions of a tax law by the Commissioner-General.
So it came to pass that in consonance with Section 100(1), the Commissioner-General of the Defendant Authority issued Practice Note Number IDT/2017/001 on 23rd June 2017.
Aggrieved by the provisions contained in the Practice Note, the Plaintiff claimed against the Defendant the following reliefs:
a. A declaration that the Defendant’s purported act of extending the coverage of the VFRS to importers of taxable goods through the aforesaid Practice Note is unlawful.
b. A declaration that by subjecting importers to both the VFRS and the standard rate of VAT whilst at the same time barring the said importers from…