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I.T.AS. NOS.2600/LB TO 2602/LB OF 2000, DECIDED ON 29TH SEPTEMBER, 2001. versus I.T.AS. NOS.2600/LB TO 2602/LB OF 2000, DECIDED ON 29TH SEPTEMBER, 2001.


Income Tax Ordinance 1979 Section 78 (4) (a) (ii) (iii), 78 (4) (c), 80AA, 50 (3), Provo and 50 (3A) First Schedule, Part I, Item (DDDD) It is the responsibility of the Convention, CL VII, P4 7 and XXI agencies to avoid double taxation between Canada and Pakistan, which represents a fee-free tax for the technical services of foreigners. The Income Tax Ordinance, 1979 was issued for a deduction at the rate of 5% and the deduction was deducted as a result of which the fee on payment to a foreign company was made non-resident under section 80AA of the Income Tax Ordinance. Was received in the hands of the Company, as agent of such non-resident company under section 78 of the Income Tax Ordinance, 1979 (15 DDD) of 1979 @ 15% of the Income Tax Ordinance, 1979 The Appellate Tribunal of the First Appellate Authority agreed on the assumption that the Income Tax Ordinance of 1979 was dealt with. Under yksn 78 where a person was or had been treated with the agent that he was responsible for the evaluation of your name in connection with the earnings estimates. A non-resident company cannot be included in the provisions of Section 7878 ()) (C) because the review of the relevant years was not assessed as an SC and, therefore, under section 78 of the Income Tax Ordinance. Under the order, the appellate tribunal accepted the appeal of this ACC approved by the two authorities under section 78 of the Income Tax Ordinance, 1979 and was canceled in 1979.

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