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I.T.A. NO. 1551/HQ OF 1988-89, DECIDED ON 16TH APRIL, 1999. versus I.T.A. NO. 1551/HQ OF 1988-89, DECIDED ON 16TH APRIL, 1999.


In order to avoid double taxation between Pakistan and France, the Income Tax Ordinance 1979 Sections 163 and 80AA Agreement, Arts III, CL (1) and Subpara 4 were exempt, specializing in a non-residential company. Received revenue from providing specialized services to civilians. The Aviation Authority specializes in the Assisi specific sector for airport construction in Pakistan and has the required professional skills, personnel and technical resources as part of its normal business activity to receive receipts under Article III of this agreement. Exemption was claimed in a series of double avoidance agreements. The tax assessment officer rejected by the tax assessing officer between Pakistan and France as a claim for commercial profits fell into the realm of professional services, which were explicitly excluded from the term industrial and commercial profits. ? Technical services fees did not fall under the purview of Indo, and profits were not exempt, therefore, income tax was levied in Pakistan.

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