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The Federal High Court (FHC or the Court ) Lagos
Division, on Monday 28 September 2020, overturned the judgment of
the Tax Appeal Tribunal (TAT or the Tribunal) in the appeal
between the Federal Inland Revenue Service (FIRS or the
Appellant ) and Total E&P Nigeria Limited (Total or the Respondent ) by ruling that petroleum investment
allowance (PIA) should be included in the computation of balancing
charge on disposal of assets used for petroleum operations.
Specifically, the FHC held that PIA granted by Paragraph 5 of
the Second Schedule to the Petroleum Profit Tax Act Cap P13, Laws