JUDGMENT
TANKO AMADU, JSC:
INTRODUCTION
1. Tax legislations, and their construction continue to engage our courts in the effort to provide certainty in the law. The entrenched position at common law remains that, tax statutes must be strictly construed and implied. The Legislature should be deemed to have intended only what they have expressed in a tax statute. It is no function of the court, to urge a certain purposive or benevolent construction at variance with the strict terms of a tax statute. In the recent decision of this court in the case of MAERSK DRILLSHIP IV SINGAPORE PTE LTD. VS. THE COMMISSIONER GENERAL GHANA REVENUE AUTHORITY, CIVIL APPEAL NO. J4/59/2024 DATED 2 APRIL 2025, where I had the privilege of delivering the lead majority opinion, I observed inter alia as follows:-
“Tax law is one area of law where enforcement and interpretation of regulatory provisions command strict construction. Under our constitutional and legislative regimes, unless the legislature or such other…