Commissioner of Taxation v Shell Energy Holdings Australia Limited [2022] FCAFC 2
TAXATION – where the respondent party to a joint venture agreement in relation to petroleum project – where joint venture participants held statutory titles which conferred authority to explore for petroleum – where respondent increased its proportional interest in statutory titles through purchase of additional proportional interest pursuant to an asset exchange agreement – whether the respondent is entitled to tax deduction under s 40-80 of the Income Tax Assessment Act 199