(a): Options Open to the Revenue Authority on Receipt of a Letter of Objection

1. Review and Revise: The Revenue Authority may review and revise the assessment if it agrees with the taxpayer’s objection, thereby reducing or adjusting the amount payable accordingly.
2. Refuse to Revise: If the Authority believes the objection is unfounded, it may refuse to revise the assessment, issuing a Notice of Refusal to Amend to the taxpayer.

(b): Content of a Notice of Objection

A valid Notice of Objection should include the following:

1. Recipient Address: Directed to the Chairman, Federal Inland Revenue Service.
2. Grounds of Objection: Clear statement of reasons, including:
   • Amount of Assessable and Total Profit for the relevant assessment year.
   • Amount of tax the taxpayer claims is payable.
3. Timeliness: Must be filed within 30 days from the date of the Notice of Assessment.

(c): Jurisdiction of the Tax Appeal Tribunal

The Tax Appeal Tribunal (TAT) has jurisdiction over the following tax-related disputes:

1. Companies Income Tax: Including cases arising under the Companies Income Tax Act.
2. Personal Income Tax: For individual taxpayers and related assessments.
3. Petroleum Profits Tax: Covering oil and gas industry assessments.
4. Value Added Tax (VAT): Resolving disputes related to VAT assessments.
5. Capital Gains Tax: Including disputes over gains from asset disposals.
6. Any Other Tax Legislation: The TAT may hear appeals on matters arising from any tax-related laws in Nigeria.

(d): Conditions for an Appeal to the Federal High Court

For an appeal to the Federal High Court to be valid:

1. Amount in Dispute: The disputed amount must not be less than N400.
2. Legal Grounds: The appeal must be based on points of law.
3. Timeliness: Appeal notice must be filed within 30 days after the TAT’s decision.
4. Grounds of Appeal: Specific legal grounds for the appeal must be clearly stated.

(e): Options for an Aggrieved Taxpayer after the Federal High Court Decision

If a taxpayer is dissatisfied with the Federal High Court’s decision, the following options are available:

1. Appeal to the Court of Appeal: The taxpayer may file an appeal to the Court of Appeal for further review.
2. Appeal to the Supreme Court: If still unsatisfied after the Court of Appeal, the taxpayer can appeal to the Supreme Court, the highest court in Nigeria, for a final judgment.