I.T.AS. NOS.364/KB, 1300/KB TO 1305/KB OF 1999-2000 versus I.T.AS. NOS.364/KB, 1300/KB TO 1305/KB OF 1999-2000
In order to avoid double taxation between Pakistan and the US, the Income Tax Ordinance 1979 Section 78 Agreement, the responsibility of the agents representing the Constitutional Permanent Establishment, was considered to be the non-resident principal's agent under Section 78 of the Income Tax Ordinance 1979, and Taxes were charged on the basis that the non-resident principal in Pakistan was charged by the assessee on the basis that the Assisi had made a distribution agreement with the non-resident principal under which the assessee was responsible for the payment of this tax. Was born as a result of the payment of a sub-license fee. The aforesaid non-resident principal asserted that the income of the non-resident principal is not taxable in Pakistan because it does not have a permanent residence in Pakistan nor is it permissible to sub-license the programs under a valid agreement between the resident principal. Was exclusive and the principal had the right to distribute the programs directly in Pakistan and for the appointment of another agent in Pakistan, only the rights to use intellectual property were given to the equipment Or articles could not be considered as idols in the definition of permanent settlement in the contract. Sub-licensing rights programs were not used by non-resident principals after that, but the rights of clients to use this program with the ability of licensors were assessed. Was operating independently and did not represent a permanent establishment. Non-Resident Principal in Pakistan Non-Resident Principal Misses in Pakistan
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