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COMMISSIONER OF INCOME-TAX versus MESSRS UNILEVER P.L.C. U.K.


The Income Tax Ordinance 1979 Section 163 was rejected by the Assistance Officer regarding taxability to avoid double taxation and a tax evasion agreement to avoid double taxation between the Pakistan and UK consultancy fees. The position of acknowledgment of the accuracy of the Income Tax Appellate Tribunal was that the fee in question was on the consultation basis and that the consultation referred to tendering advice and consultation and of course consultancy fees were not managed, controlled or monitored so industrial and commercial profits. In which the tax was taxable. Pakistan

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