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I.T.A. NO.1150/KB OF 2005, DECIDED ON 9TH JANUARY, 2007. versus I.T.A. NO.1150/KB OF 2005, DECIDED ON 9TH JANUARY, 2007.

Sections 12 (5) and 80AA were considered to be accumulated or generated in Pakistan, but the cost compensation was considered as a fee for technical services but no evidence was supported in support of such treatment. It was proved that the assessee was only re-paid. Failure to establish a departmental officer was the income of the recipient already required to be taxed under section 12 (5) of the Income Tax Ordinance, 1979 Department Officer. Nothing was brought to the record for the suggestion that the receipt had a revenue feature or that it had received money during the year under consideration. Or was it the definition of a definition fee for technical services that was on record that the payment to Esmecii was merely a reimbursement of certain costs and did not come into the definition of income definition? Not sustainable in law, which was rightly canceled by the first appellate authority. \ r \ n \ r \ n tax advocates from Okara lawyer