C.I.T., LEGAL DIVISION, L.T.U., LAHORE versus SANPAK ENGINEERING INDUSTRIES, LAHORE
Sections 21 (c), 161, 6 (2) (c) and 107 (2) avoiding the double taxation agreement between Pakistan and Japan, the deductions of Arts VII and VIII increased royalties due to royalties. Not allowed to delete The taxpayer had a legal obligation to deduct the tax due on royalty payments to the nonresident company and that the taxpayer company was in compliance with the provisions of section 21 (c) of the Income Tax Ordinance 2001 Was unsuccessful, and was said to be due to royalty. The taxpayers claimed that under Section 107 (2) of the Income Tax Ordinance 2001, which deals with the implementation of double taxation agreements, violates any tax law, against which, the first The order to delete the appellate authority was not sustainable under the law. Applicable to the country. That the taxpayer has obtained exemption from tax deductions on remittances due to royalties in light of the provisions contained in Articles VII and VIII of the avoidance of double taxation agreement between Pakistan and Japan as well as Section 6 (2) of the Income Tax. (c) Ordinance, 2001; In accordance with the provisions of section 152 of the Income Tax Ordinance 2001, deduction of tax on payments made to a non-resident company was not applicable due to royalties and the Commissioner of Income Tax The tax deduction on payments due to self-royalty was exempt. Exemption from tax on royalty paid to a non-resident company under a double taxation contract avoidance agreement under a tax-paying company between the governments of Japan and Pakistan. Want permission
