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ORICA GHANA LIMITED
V.
THE COMMISSIONER-GENERAL GRA

(2026) JELR 115372 (CA)

Court of Appeal 22 Jan 2026 Ghana
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- The Ghana Revenue Authority (GRA), following a 2017 tax audit, apportioned the Respondent’s business income into manufacturing and non-manufacturing (management service) activities, thereby limiting the Respondent’s location incentive and

Case Details

Suit Number:H1/22/2025
Judges:MENSAH-DATSA (MRS.), JA, AHMED (MRS.), JA, ARMAH-TETTEH, JA

JUDGMENT

This is an appeal by the Respondent/ Appellant (hereafter referred to as Appellant) against the judgment of the High Court, Accra, Commercial Division dated 19th July, 2022 (as an appellate Court) in favour of the Appellant/Respondent (hereafter referred to as Respondent).

The grounds of appeal are stated at page 203 of the Record of Appeal as follows:

“a. The Judgment is against the weight of evidence.

b. The decision of the High Court to accept as authentic the disputed photocopied VAT Relief Purchase Orders (VRPOs) is against the weight of evidence.

c. The High Court erred in law by holding that the Respondent erred in apportioning of the Appellant’s business income into manufacturing and management service.”

Particulars of error of law

“i. The High Court misconstrued the meaning and effect of Article 296 (c) of the 1992 Constitution on the exercise of discretionary power.

ii. The High Court misconstrued the meaning and effect of Section 58(4) of the Internal Revenue Act, …

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