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ABN AMRO BANK (ROYAL BANK OF SCOTLAND) versus TAXATION OFFICER III, AUDIT DIVISION LARGE TAXPAYER UNIT, KARACHI


Sections 2 (40), 11 (6), 101 (3) and 105 Pakistan Branch of a Non-Residential Banking Company, which is loaned by or through the Pakistan Branch or by the Head Office and other branches of such company Interest on / Profit. Outside Pakistan, the scope of the negotiation may not be taxed and applied pursuant to section 105 (1) (a) of section 101 (3) and 105 of the Income Tax Ordinance 2001 and Must read regularly. The permanent branch of a non-permanent banking company in Pakistan will be considered as a separate and separate entity and will be considered to operate independently when dealing with headquarters or other branches of its company located outside Pakistan. The resident, directly or indirectly attributable to a permanent establishment in Pakistan, shall be deemed to have earned Pakistan's source of income on the loan paid or payable by the Pakistan Branch in connection with this agreement. GSS's head office and other branches of a non-residential banking company will be considered as its revenue and deduction costs, respectively.

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