INTERQUEST INFORMATION SERVICES versus COMMISSIONER OF INCOME TAX
Sections 30, 33 and 136 Agreement to Avoid Double Taxation between Pakistan and the Netherlands, Article 12 3 Double Taxes Business Profit or Royalty Assessment Receipts were obtained by leasing FLIC tapes to the Income Tax Appellate Tribunal From parties not related to revenue and business profits clearly showed that the payment received by Assisi was not for the use or exploitation of copyright patents, know-how, secret process or formula or specialized knowledge, invented Or for patent supply but for its commercial use of the patent software product and system. This product can only be used for its technical use and cannot be transmitted to any other person, therefore, it is not appreciated as royalty as in Article 12 of the double tax treaty between Pakistan and the Netherlands. Is described in para 3 of If the order of the Income Tax Appellate Tribunal could not be obtained, it was answered accordingly to retain the profitability of the business in the second income, and to set aside the right of assessment.
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