The overcharge arose from disallowance of expenses linked to Petronas’ overseas country-office related expenses for that year. In delivering the court’s decision, Justice Wong said the High Court and the Special Commissioners of Income Tax (SCIT) had erred in ruling that Petronas was not entitled to deduct its office-related expenses under PITA. He also said both High Court and SCIT should have decided that the country-office expenses had been expended by the company outside Malaysia. He said the DGIR is to refund RMRM11,392,044 and RM4,280,556 to Petronas within six months from today. “With the agreement of both parties, no order as to costs for this appeal, proceedings in the High Court and before SCIT,” he said.