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Section 80A, 50 (3A) and 12 (5) double taxation agreement between Pakistan and U Section A, Article XII Technical Service Fees assess the tax on non-resident income tax on source in default The deduction was paid to the non-resident through the SC / Company and to the non-resident shareholders of Pakistan through illegal shareholders. And this assessment / company was defaulted on default for tax deduction. However, the taxation officer did not establish that the claim expense was not related to income earned in Pakistan on the basis that it was solely for a business operating in Pakistan as was paid wisely to non-residents. There is no fixed base in Pakistan to receive such payments. The ACCC was required to deduct the tax under section 50 (3) of the Income Tax. Tax Ordinance, 1979 Only when the income from payment increases which tax is imposed in Pakistan The tax officer imposed the tax without realizing that the tax authorities only received tax from the tax department of Pakistan. Given the option to earn from such income. The tax officer in Pakistan did not make any inquiry to ascertain whether the persons on whom there was a fixed basis were paid and failed to establish a tax deduction, in the following years, the tax That was not the way the officer was treated. The department itself approved best advocate from Usta Mohammad lawyer