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I T.A NO.2241/KB OF 1998-99 versus I T.A NO.2241/KB OF 1998-99


Income Tax Ordinance 1979 Articles II (1) (1), II paragraphs (ii) and III (1) Income Tax Ordinance (1979), Section 27 CBR Letter No. 2 (3) IT II / 77 dated 20 11 Exempt from the 1982 capital industrial or commercial profit, was an unexpected company engaged in the business of communication and related activities in Pakistan, Skasey acquired Engaged Equity Capital / Share in Pakistan for more than five years. The surplus value of this asset was exempt from tax. In Pakistan, the profits made on the sale of such shares under Article III of the Convention were included in the term in industrial or commercial profits as used in Article II (1) (1) of the Convention / Tax Contracting Assessment Officer. ? The term industrial / commercial profit was not defined in this tax / tax agreement, and therefore, on the basis of Article II (2) of the tax agreement, the profit on the sale of such shares was taxed - in the capital. Valuation of Val property obtained under domestic law is obtained through property as industrial and commercial profits are different from the sale of capital assets in accordance with Article II of the Capital Convention Law and its valuation for the year. During the live drug. The relevant case will apply to the matter of the SC and in the absence of express orders regarding the waiver of any item or waiver of any item in an agreement or convention, the provisions of the domestic law apply to the waiver claim rejected by the Assessing Officer. Will be on Certified by the Appellate Tribunal

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