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I. T. AS. NOS. 1601/KB AND 1602/KB OF 1985-86, DECIDED ON 31ST MARCH, 1994. versus I. T. AS. NOS. 1601/KB AND 1602/KB OF 1985-86, DECIDED ON 31ST MARCH, 1994.


Income Tax Ordinance 1979 Section 163 Income Tax Rules, 1982, 20 Conventions to Avoid Double Taxation Between the Islamic Republic of Pakistan and the Federal Republic of Germany, Article III (4) A Non-Resident Head Office Expenditure Eligibility Convention Examined That the expense of the permanent establishment be allowed to the duty of the appointing officer and the appraisal officer with the General Administration, 20 In the presence of a double taxation convention, avoid the income tax rolls 1982 The provisions contained in the Convention are not valid. The provisions contained in the Income Tax Ordinance will be double taxed. 1979 The Assessing Officer must, however, examine the details of expenditures and allow for those expenses, which are allotted for a permanent establishment, including expenses for the executive and general administration if the AssisiC claims any expenditures that reasonably The expenses incurred by the Permanent Establishment have to be denied where the Assessing Officer increased the account of the SC by adopting R20, Income Tax Rules, 1982, the Commissioner Income Tax (appeal) Exclusion was not considered to be valid. The addition of the proper direction by the commissioner would have put this issue aside

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