INTERNAL REVENUE SERVICE
V.
MULTICHOICE (GH) LTD

JUGDEMENT

OSEI JA

The undisputed facts of this appeal are that: Multichoice (Gh) Ltd, the plaintiff-respondent (hereinafter referred to as the respondent) 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 respondent without dispute, incurred losses from its television business as such but made substantial gains from its banking account by way of interest. The respondent 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 (hereinafter referred to simply as the appellant) 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 as being two separate sources of income. When the …