PAKISTAN TELECOMMUNICATION COMPANY, ISLAMABAD versus C.I.T. (LEGAL) LARGE TAXPAYERS UNIT, ISLAMABAD
Article 21 (c), 152, 122 (5A) and 177 Avoiding the double tax tax agreement between Pakistan and the UK, Article 12 (3) paid the taxpayers a satellite communications company due to satellite charges. Lets not pay outgoing royalties. In the light of the provisions contained in section 2 (54) of the Income Tax Ordinance 2001, Pakistan and the United Kingdom and the Income Tax Ordinance 2001 between Article 12 (3) of the Double Taxation Tax Agreement, as well as the use of foreign satellite company transponders. The taxpayer was included under section 21 (c) of the taxpayer, the telecommunications company, claiming that the transponder, despite being a scientific device, was not under its control and could not be used for use or rights. The nature of the scientific equipment and the contract proved that the satellite or transponder was not leased to taxpayers. And the agreement was only for the acquisition of telecommunication services, which falls within the purview of Article 7 of the contract and should be considered as commercial profit that the transporters were receiving licensed telecommunication services from the taxpayers and The consideration paid to a non-UK based company was the payment / consideration royalty for the services received by Scientific Instruments and expenses were not allowed under section 21 (c) of the Taxpayers Income Tax Ordinance 2001 The extent of the grant was appealed by the appellate tribunal.
