Whether the services offered by Cybercash Limited to the
Appellant are in the nature of management services for which
the Appellant should have remitted withholding tax.
Whether interest expenses incurred by the appellant can be restricted in proportion to the appellants loan advances to related parties including Cybercash Ltd over total bank loans for income tax purposes

I. A declaration that the Appellant the full interest on its Respondent.
ii. A declaration that Cybercas limited is in the business of selling
a virtual product and not providing a manage
all, hence the 'g':' made by the Appel
Limited are not s withholding tax.
iii. The Respondent' taxes dated 20th
November2012 and confirmation on assessment dated 17th April
2015 be struck out in their entirety.
1he Respondent, its employees, agents or other persons
Purporting to act' on its behalf be barred from demanding or
taking any further steps towards enforcement or recovery of
principal tax, permits and interest on any of the Respondent's
demands stipulated in their notice of assessment dated 20th
November 2012 and confirmed vide the letter of 17th April 2015

v. The costs of this Appeal.

VI. Any other remedies that the Honorable Tribunal deems just and
reasonable

The appeal lacks merit and is hereby dismissed

The tribunal affirms the decision of the commissioner in confirming the assessment dated 16/04/2016