Dr Cyril Obika of the Faculty of Law, Enugu State University of Science & Technology, Enugu Nigeria in his article, An Analysis of the Power of the FIRS to Assess Tax on Turnover: A Review of Theodak v FIRS posits that ordinarily the FIRS, under section 9 of the Companies Income Tax Act 1961 as amended (CITA) charges to tax the profits of a company on its income> accruing in, derived from, brought into, or received in Nigeria. Exceptionally, under section 30 CITA the FIRS may charge a ‘fair and reasonable percentage’ of the turnover of a company to tax where there is no assessable profit or the profit is less than expected of such a business. Again, the FIRS under section 65 CITA may use its ‘best of judgment’ to assess tax where a company fails to file a return. Can the property of a company let to tenants be its turnover? Dr Obika examines the interrelation of sections 9, 30 and 65 of the CITA in his review of Theodak v FIRS.