The ATTOCK OIL COMPANY LIMITED vs CENTRAL BOARD OF REVENUE, ISLAMABAD S — 2023 PTD 455 ISLAMABAD

Case information

Citation: 2023 PTD 455 ISLAMABAD
Court: Islamabad High Court
Year: 2023
Reporter: PTD
Parties: The ATTOCK OIL COMPANY LIMITED vs CENTRAL BOARD OF REVENUE, ISLAMABAD S
Subject matter: Tax & Customs
Provisions referred to: S. 133---I; S. 26; Income Tax Ordinance (XXXI of 1979); Income Tax Ordinance

Fields are extracted from the reported citation and judgment text. Where a detail is not stated in the record, it is not shown.

Judgment text as reported

The ATTOCK OIL COMPANY LIMITED VS CENTRAL BOARD OF REVENUE, ISLAMABAD S.133---Income Tax Ordinance (XXXI of 1979), S.26(b), Fifth Schedule, Part-I, Rr.3 & 6(10)---Pakistan Petroleum (Exploration and Production) Rules, 1986, Rr. 2(k) & 38---Reference---Wellhead value---Depletion allowance, calculation of---Deduction of royalty amount---Issue was with regard to calculating depletion allowance and deduction of amount of royalty---Validity---Wellhead value under R.2(k) of Pakistan Petroleum (Exploration and Production) Rules, 1986, meant market value of petroleum as calculated for the purposes of R.38 of Pakistan Petroleum (Exploration and Production) Rules, 1986, after excluding gathering, processing, treatment and transportation costs of such petroleum---Definition of wellhead value as incorporated by reference in R.6(10) of Part-I of Fifth Schedule to Income Tax Ordinance, 1979, did not allow reading into such definition exclusion of royalty payable by petroleum exploration and production companies to government for purposes of calculation of depletion of allowance under R. 3 of Part-I of Fifth Schedule to Income Tax Ordinance, 1979---For the purpose of calculating depletion allowance under R.3 Part-I of Fifth Schedule to Income Tax Ordinance, 1979, amount of royalty paid by taxpayer to government was not to be deducted while computing wellhead value---Reference was disposed of accordingly.

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