JUDGMENT

SARDAR EJAZ ISHAQ KHAN, JUSTICE:---.---The question of law for us to answer in these sales tax reference applications under section 47 of the Sales Tax Act, 1990, was framed by our predecessor Bench in STR 17/2021 as follows:Whether the learned ATIR has erred in concluding that ‘condensate' is not part of the same family of petroleum oils as ‘crude oil' and hence incorrectly determined tax liability against the petitioner?Whether the impugned judgment incorrectly interpreted the application and provisions of SRO number 549 of 2008?From the written and oral submissions, the following further question of law has arisen: Whether the zero-rating was available only for petroleum crude oil ‘imported and supplied' or whether import was not an essential condition?The applicant companies were engaged in the business of exploration, production, and sale of petroleum and natural gas. They did not charge sales tax on the sales of ‘condensate' for various tax periods in the belief that the ...