ORDER:

SYED MANSOOR ALI SHAH, JUSTICE:---The question before us is whether income arising from container detention charges (CDC), container service charges (CSC) and terminal handling charges (THC) falls within the category of profits from the operation of ships in international traffic in the context of double taxation conventions concluded between Pakistan and Denmark, as well as between Pakistan and Belgium.2. The respondents are non-resident companies, one incorporated in Denmark and the other in Belgium. They are involved in cargo shipping activities, conducting their business operations within Pakistan through the authorized agent, M/s Maersk Pakistan (Private) Limited. The respondents filed income tax returns, accounting for income derived from freight charges, CDC, CSC and THC. They claimed entitlement to tax benefits under Article 8 of the Convention between the Islamic Republic of Pakistan and the Kingdom of Denmark for the Avoidance of Double Taxation and the Prevention of Fiscal E...