1998 PTD 291 INCOME-TAX-APPELLATE-TRIBUNAL-PAKISTAN

1998  PTD  291     INCOME-TAX-APPELLATE-TRIBUNAL-PAKISTAN

I.T.AS. NOS.905/113; 906/113 OF 1991-92, 963/113 OF 1993-94, 1053/IB, 1054/IB, 960/113

Income Tax Ordinance 1979 —S. 26(b) & Fifth Sched., Part I, R. 6(6)—Pakistan Petroleum Production Rules, 1949, R. 41—Regulations of Mines and Oil fields and Mineral Development (Government Control) Act (XXIV of 1948), Ss. 2, 3-A & 4–Income from exploration and production of petroleum—Liquefied petroleum Gas (L.P.G.) and Petroleums, crude Oil , natural Gas and casing-head petroleum spirit—Natural—Expression “petroleum” had not been defined in Fifth Sched to Income Tax Ordinance, 1979 but by way of legislation by reference, the definition contained in Pakistan Petroleum Production Rules, 1949 had been incorporated with further restriction that refined petroleum would not be included in the said definition– “Petroleum”, meant crude Oil , natural Gas and casing-head petroleum spirit but excluded refined petroleum products —Liquefied petroleum Gas (L.P.G.) being mainly consisting of propane and butane was to be taken as crude Oil , natural Gas and casing-head petroleum spirit with exclusion of refined petroleum products.