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R. AS. NOS. 266/KB TO 273/KB OF 2002, DECIDED ON 24TH JUNE, 2002. versus R. AS. NOS. 266/KB TO 273/KB OF 2002, DECIDED ON 24TH JUNE, 2002.

Income Tax Ordinance 1979 Section 136 Referring to the High Court Convention for the Prevention of Double Taxation between Pakistan and Japan, dated 1 1 1959, Article VII, CL (3) Promoted Estoppel Royalty Technical Fees 1% in Tact Fees Distribution of royalties (1% of 25%) and royalties (75% of 1%), which is sustained by tribunal questions for reference whether the tribunal was legally justified in providing technical services Whether some element of the fee was hidden in the royalty announcement payment. The justification for upholding the royalty payment declaration declared by the Assessing Officer, especially when the case is in contravention of the principle established by the Priory Estoppel for reference in the High Court for voting and the legitimate right of the Assessee / Appellant. There was illegal interference with reference. The first reason was not admissible for the reasons that this order states that its nature has raised some questions of the law only in this case its case was limited to the extent that It was only in the cases that a factor in the fee for technical services was identified and it was assumed that the matter was referred to the High Court, then any decision could be resolved as a result of any factual dispute. And second, the questions that were formulated were not of public importance, which are generally applicable on many issues. Retain reference requests. Did not appear to be able to be rejected by the tribunal. pakistani advocates Sidhnoti lawyer