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Supreme Court of Pakistan 2023 Income Tax Ordinance (XLIX of 2001)

2023 PTD 863

Conventions/ Exemption/ permanent establishment
SNAMPROGETTI ENGINEERING B.V. through Special Attorney
Appellant
VS
COMMISSIONER OF INLAND REVENUE ZONE-II, L.T.U, ISLAMABAD and others
Respondent

Case Laws / Head Notes / Paras

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...