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 Danish Double Tax Tax Agreement (DTA) was not included in the Danish Duty Tax Agreement (DTA) in relation to the profits from internationally-operated ships, with respect to Pakistan's tax-deduction. The two reasonable interpretations of the agreement or the interpretation of doubt or ambiguity in the interpretation of the contract derive from state sources as to the profits, as used in this, Excerpt will be resolved in favor of the paying Pakistan. The source state will be considered as the state in which payment is made and will be entitled to tax on such payments. The carrier will be entitled to freight only if the goods are actually at port In the present case, the port was the destination of Pakistan. In this case, the carrier made the income, ie the goods and the actual payment was within Pakistan. In the present case the payment was made by a Pakistani buyer. Reasonably Pakistan's profits from such a source of profits from inside sources Can be counted in favor of. Principles
