Facts:

The appellants as employees of Mobil Producing Nigeria Unlimited Eket, Akwa Ibom State appealed against the imposition of additional taxes on them. The Akwa Ibom State Military Government forwarded a debit advice to the employers of the appellants in the sum of N117,806,877.50 as under collection of PAYE tax for 1989-1994 due from the employees (appellants). In reaction Mobil Producing Nigeria Unlimited, (hereinafter called Mobil) wrote to the Government arguing that it had no statutory duty to assess or determine the tax payable by its employees not being the taxing authority and that it was not liable for any tax underpayment in amounts it correctly deducted in accordance with official tax card duly prepared, endorsed and stamped by the Tax Authority.