Department Of Commercial & Industrial Law

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DEDUCTIBLE EXPENDITURE UNDER THE PETROLEUM PROFITS TAX ACT: Shell Petroleum Development Company v. FBIR
(Faculty of Law, Lagos State University, 2001) SANNI, A.O
The case of Shell Petroleum Development Company v Federal Board of Inland Revenue typifies the usual contest of claims between the taxpayer and the tax authority over deductible expenses. The case is significant in many respects. First and foremost, it is the first pronouncement ever by the Supreme Court on the provisions of the Petroleum Profits Tax Act, as amended. Second, it is the only tax case decided by the court after the Marina Nominees Ltd. v. FBIR since 1986, a space of ten years apart. Third, it is one of the few cases that have gone through the entire stages of the tax appeal process from the Federal Body of Appeal Commissioners to the Supreme Court. Fourth, the case was a battle royale fought by the parties for almost two decades.