2012 PTD 734

Case Laws / Head Notes / Paras

---Avoidance of Double Taxation Treaty between Pakistan and Japan, Arts. VII & VIII---Deductions not allowed---Royalty---Deletion of addition made on account of 'royalty'---Revenue contended that taxpayer was under legal obligation to deduct tax on payments made on account of royalty to non-resident company and that taxpayer company had failed to comply with the mandatory provisions of S.21(c) of the Income Tax Ordinance, 2001, addition made on account of royalty was quite justified against which, deletion order by the First Appellate Authority was not sustainable under the law---Taxpayer contended that S.107(2) of the Income Tax Ordinance, 2001, which related to implementation of agreements for Avoidance of Double Taxation, override any tax law enforceable in the country; that taxpaye...