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I.T.A. NO. 307/PB OF 2001-02, DECIDED ON 27TH MAY, 2002. versus I.T.A. NO. 307/PB OF 2001-02, DECIDED ON 27TH MAY, 2002.


Income Tax Ordinance 1979 Sections 66A, 62, 11 and 12 Convention to avoid double taxation between Pakistan and Germany, Article 7 Permanent Establishment Assistance was a non-German company and the return of the turbine installation for the hydropower project The net declaration of damages from its permanent stay in Pakistan was assessed after supporting some increase in the claimed costs of this assessment which was examined by the Additional Commissioner, Section 66 of the Income Tax Ordinance 1979. Was under A. Business transactions attributed to both coastal and coastal activities should have been taxed as manufacturing activities outside Pakistan could not be distributed for taxation purposes as part of a comprehensive agreement. And the activities of the coast were directly linked to the permanent establishment. Coastal activities were a necessary extension of Wally's provisions of section 12 (2) of the Income Tax Ordinance 1979, provided that in the case of non-resident, his income was only taxable on the part of Pakistan. Under section 62, Pakistan is entitled to a permanent establishment in the Order. The Income Tax Ordinance 1979 was passed by the Assessing Officer after reviewing various aspects of this case, the terms of the agreement and the provisions of Article 7 and Para 2 (a) of the Convention, and it rightly decided that the SC Only a portion of the income was liable to be taxed in Pakistan because the Income Tax Ordinance, under section 62 of the 1979 Income Tax Ordinance, was neither stable nor wrong on coastal activities. A.

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