SUPERNET LIMITED KARACHI versus C.I.R., ZONE-II, L.T.U., ISLAMABAD
Sections 127 and 152 Using the Satellite's technical facilities Avoiding double taxation by non-resident payments The taxpayer's payment is considered royalty rather than industrial / commercial profit. Appellant's contention was that he did not use any intellectual property. The use of hardware, software, infrastructure and equipment as a royalty but also a satellite receiver is owned by a non-resident who is housed in the upper space and anyone can purchase a satellite facility that has a local There was a ground-based facility available as the recipient, so this kind of payment could happen. Not treated as royalty. Payments by taxpayers were significantly related to royalties because the use of satellite and no other intellectual property, such as trademarks, copyrights or patent commissioners in the upper space installed by anyone, intensified, The focus of the period and the activities achieved in it was the presence of both contracting parties or alternative options available to taxpayers, namely the presence of other parties in the open market, controlling the ownership and operational management of technical equipment. Normalizing money supply despite mutual dependence Mjha was. Business expenses
