In this paper, we reviewed the conflicting decisions of the South-South Zone of the Tax Appeal Tribunal in Ellah v. FIRS (Appeal No. TAT/SSZ/001/2019), which was delivered on 9 September 2020 and the Lagos Zone of the Tax Appeal Tribunal in Ess-ay Holdings Limited v. FIRS (Appeal No. TAT/LZ/VAT/029/2019), which was delivered on 10 September 2020 regarding the charging of Value Added Tax on the rental income from properties.