ORDER

MUNIB AKHTAR, J.---At the conclusion of the hearing it was announced that this leave petition was being converted into an appeal and allowed. The following are the reasons for our decision.2. The matter arises under the Federal Excise Act, 2005 ("Act"). The relevant facts can be stated with brevity. The respondent taxpayer is a franchiser within the meaning of that term as set out in Rule 2(mb) of the Federal Excise Rules, 2005 ("Rules"), which have been framed under the Act. The term "franchise" is defined in section 12(12a) of the Act. The taxpayer, a Pakistani company, entered into various franchise agreements with parties in Pakistan, and this constituted the providing of dutiable services (within the meaning of section 2(8d) of the Act) in Pakistan, as "franchise services" are set out as excisable services in Table II of the First Schedule to the Act. The period relevant for present purposes is 2012. The point in dispute is the person by whom the excise duty was payable in relatio...