BIOBELE ABRAHAM GEORGEWILL, J.C.A. (Delivering the Leading Judgment): This is an appeal against the ruling of the High Court of Oyo State, Ibadan Division, Coram: O. M. Olagunju J, in Suit No. I/598/2021: Sidex Consulting Limited V. Oyo State Board of Internal Revenue & Ors delivered on 17/2/2023, in which Relief No. A of the Respondent as Claimant was granted against the Appellants as Defendants under the Summary Judgment Procedure, whilst Relief Nos. B-F were set down for full trial at plenary.
The Appellants were peeved with the said ruling and had appealed against it vide their Notice of Appeal filed on 17/3/2023 on two Grounds of Appeal. See pp 216-218 of the Record of Appeal. The Record of Appeal was compiled and transmitted to this Court on 25/5/2023. Subsequently, with the leave of Court, an Amended Notice of Appeal was filed on 7/4/2025 on two Grounds of Appeal and was deemed as properly filed on the 25/9/2025. The parties filed and exchanged their briefs, namely: The Appella…