Facts:

Facts:

The appellant and 1st respondent are parties to a Production Sharing Contract (PSC) concerning an Oil Mining Licence (OML) 130 over a Contract Area (the Contract Area) in which another company, Total Upstream Nigeria Limited is the Operator of the Contract Area. In accordance with the PSC, Total Upstream Nigeria Limited prepared the Petroleum Profits Tax (PPT) returns for the 2010 accounting year in respect of the Contract Area and sent same to the 1st respondent for filing with the 2nd respondent. However, the 1st respondent failed to file the returns instead unilaterally prepared and filed another returns with the 2nd respondent. Relying on the returns filed by the 1st respondent, the 2nd respondent assessed the Contract Area for the purpose of Tertiary Education Tax and served the Notice of Assessment on the appellants in October, 2011.

The Operator on behalf of the appellants filed a Notice of Objection challenging the Notice of Assessment on the ground that it believed that it was incorrectly prepared. The 2nd respondent after receiving the Notice of Objection replied by sending a letter to the Operator stating that the objection had been “noted for memorandum purposes only”. The appellants, being dissatisfied with the response, filed an appeal to the Tax Appeal Tribunal on the ground that the assessment was wrong. After being served, the 2nd respondent challenged the appeal on several grounds one of which was that the appellant lacked the locus to appeal to the Tax Appeal Tribunal since the returns were not filed by the appellants but by the 1st respondent and that non-joinder of the 1st respondent rendered the appeal incompetent. The Tax Appeal Tribunal in its ruling delivered in June, 2012 dismissed the objection of the 2nd respondent and went ahead to join the 1st respondent in the matter.

After being served with the joinder, the 1st respondent filed a Notice of Preliminary Objection challenging the jurisdiction of the Tax Appeal Tribunal to hear and determine the appeal on grounds which bordered mainly on the allegation that the claims before the Tax Appeal Tribunal were connected with taxation of companies carrying on business in the Federal Republic of Nigeria, and as such only the Federal High Court has the jurisdiction to the exclusion of any other court to entertain the matter. In its ruling of February, 2013 the Tax Appeal Tribunal held that it has the requisite jurisdiction to entertain the appeal while striking out the 1st respondent. The 1st respondent was dissatisfied with the ruling and consequently filed a Notice of Appeal at the Federal High Court, Lagos Division urging it to overrule the Tax Appeal Tribunal.

After hearing the parties, the Federal High Court Judge gave his ruling on the 22nd of May 2015 in which it held that the appellant had no locus standi to initiate the appeal and that the Tax Appeal Tribunal lacked jurisdiction to entertain the appeal as the subject matter is connected with the taxation of a Nigerian company which is an exclusive duty of the Federal High Court. The court also held that the non-joinder of the 1st respondent was fatal as it strips the Tax Appeal Tribunal of jurisdiction to hear the appeal. The appellants became aggrieved and filed a Notice of Appeal at the Court of Appeal, Lagos Division. One of the issues raised for determination was whether the jurisdiction of the Tax Appeal Tribunal to entertain the appellants’ appeal infringed on the exclusive jurisdiction of the Federal High Court to hear tax disputes as stipulated under section 251 of the Constitution of the Federal Republic of Nigeria, 1999.