A.P. MOLLER THROUGH MAERSK PAKISTAN (PVT.) LTD. versus COMMISSIONER OF INCOME TAX, ZONE I, KARACHI
Sections 7 (1) (b), 101, 107 (2) and 239 (10) Non-Resident Shipping Carrier Profit earned on restricted cargo due to freight in Pakistan through sources within Pakistan Scope Pak The tax on the Danish Double Taxation Tax Agreement (DTA) did not include the infringement of Pakistan's right to receive revenue in connection with the profits from international traffic ships, if the DTA's In the event of two reasonable interpretations or the possibility of doubt or ambiguity in its interpretation, the agreement in respect of the expression is obtained by the State sources. As a function, which is used in it, as well as the right to receive tax in favor of Pakistan, the source state will be defined as the state in which the payment is made and the tax on such payments. Will be entitled to carrier freight charges. Only if the goods were actually delivered to the port. In the present case, the port was the destination of Pakistan, through which both the terminals of the event were within the carrier's actual revenue, the goods' vehicle and the actual payment, within Pakistan. The payment made by a Pakistani buyer, thus, the profits earned through such a carrier from sources within Pakistan can be reasonably calculated in favor of Pakistan's tax. Principles
