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Convention between the Kingdom of the Netherlands and the Islamic Republic of Pakistan for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income ("Convention"), Arts. 5 & 7---Non-resident company--- Engineering services provided by the petitioner (non-resident company) to a local company---Exemption from tax under the domestic tax regime of Pakistan---Petitioner (non-resident company) and the local company did not have a contractual relationship ascribing any building construction, installation, assembly project or supervisory activities role to the former-Rather, the role of the petitioner was limited to providing engineering services only---Tax department failed to bring on record any evidence satisfying the threshold requirement of Cla...
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