MUHAMMAD SHAH versus COLLECTOR OF CUSTOMS (APPRAISEMENT)
Sections 78 and 79 can be levied on non-resident companies in Pakistan only on income earned in the territorial limits of Bangladesh. After separation from Pakistan, the identity of the Government of Pakistan will be related to that date. When the new state was formed, the income that could have been earned by the 15th of 1971 was the revenue collected within the territory of Pakistan and it was obliged to levy tax only because the purpose of earning profit was from 31st 1971 to 1971. The whole year could not be completed, it cannot be said that for the remaining period of 11/2 months, profit cannot be determined or Cannot be subject to tax. Taxes can be taxed on income that has accrued to the date when East Pakistan was a part of Pakistan.
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