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I.T.AS. NOS.530/IB TO 533/18 OF 1999-2000 versus I.T.AS. NOS.530/IB TO 533/18 OF 1999-2000


Income Tax Ordinance 1979 Sections 80A, 12 (5) (7), 30 (2) (B), 22 and 62 CBR Circular No. 2 (3) IT / 2, dated 20 11 11 1982 Government of Pakistan and Government A section A, Arts II (1), III (1) and III (3) tax avoidance of taxation on UK non-resident income tax assessor / company to avoid double taxation I was registered in which maintains a branch office in Pakistan. The Income Tax Ordinance was assessed under Section 80AA of 1979, which the first appellate authority held with the remarks that Section 22 of the Income Tax Ordinance 1979 had to be taxed on industrial and commercial accounts. Instead of Section 80AA of the Income Tax Ordinance 1979, the convention's profitability was affected by the fact that the fee for technical services falls in the industrial and commercial profits, as defined in Article II (1) of the Convention's Accuracy. Section 30 (2)) (a) Fees for technical services under Income Tax Ordinance, 1979 Income Tax Ordinance from other sources, not under income from business or profession under section 22, as income Receive. Tax services were charged at the flat rate of tax under section 80AA of the Income Tax Ordinance 1979. Read section 30 (2) and section 80A of section 12 (5) of the Income Tax Ordinance 1979, so the fee for the assessment income technical services was levied on flat rates in Pakistan and not income. Income from business or profession under section 22 of the Tax Ordinance 1979

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