RULING
DORGU, J.
On the 8th of November, 2021, the Appellant herein, Seadrill Ghana Operations Ltd filed in this Court a Notice of Appeal against the Tax assessment by the Respondent and its consequential objection decision dated the 8th of October, 2021. Upon service of the Notice of Appeal on Respondent, he also filed on the 23rd of November 2021 an application on notice praying the Court to strike out and dismiss the Tax Appeal filed by the Applicant pursuant to the inherent jurisdiction of the Court on the basis that the said appeal was filed out of time and in contravention of Section 44 of Revenue Administration Act, 2016 (Act 91-S) and Order 54 Rules 2(1) and (2) of the High Court (Civil Procedure) Rules, 2004 (C.1.47). The Respondent accompanied the notice with a 17 paragraph Affidavit in support to which he attached various exhibits. I will reproduce the pertinent paragraphs which I think are paragraphs 7 through 12 of the Affidavit in Support for their full effects.
"7. That pe…