GENERAL INTRODUCTION
1.1 Background to the study
Income tax is wholly the creature of statute. That is to say, there is no common law of
taxation. No principles of law are applicable other than those principles, which are found in the
taxing Acts themselves according to their true meaning and effect. In any tax case, it is
consequently necessary for the court or tax commissioners to determine the true meaning and
effect of the particular statutory provisions in question. The actual problem in connection with
tax administration is that of enforcing tax payment. It is against this background that the Personal
Income Tax Act of 1993 (as amended)1 as well as Companies Income Tax Act of 1990 (as
amended) made penal provisions against any violations of their provisions. These are categ
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