Law:

Section:

Keywords: Non Obstante Clause, Novation, Appellate Tribunal, Goods And Services, Place, Conviction, Refusal, Conditions, Prima Facie, Language, Enterprises, Preamble, Discharge, Outside Pakistan, Head Of Income, Allowances, Absence Of Agreement, Remittance, Dividends, Issuance Of Notice, Renunciation, Establishment, Government, Contract, Provisions, Change, Exports, Recovery, FO, Proceeds, Foreign-Source Income, Taxable Income, Prejudice, Profits, Commission, Imposition, Publication, Description, Substitution, Dispute, Securities, Banking Companies, Office, Exemption, Precedent, Discretion, Ownership, Tax Year, Sale Of Shares, Carrier, Assessment Order, Division, Notice, Show Cause Notice, Liabilities, Land, Delivery, Statutory Instrument, Copy, Express Renunciation, Tax Liability, High Court, Receipt, Receipt Of Income, Air Transport Income, Question Of Law, Qualification, Commissioners, Issuance, Remuneration, Determination, Distribution, Selling, Binding, Parties, Ambit, Expenses, Property, Evidence, Proceedings, Pakistan-Source Income, Technical Services, Functions, Jurisdiction, Exchange, Order, Connotation, Liberal Interpretation, Manufacturing, Double Taxation, Validity, Disallowance, Methods, Classes, Money, Representative, Place Of Accrual, Collection Of Tax, Constitution, Grounds, Exception, Notices, Liability, Management, Document Of Title, Statutory Interpretation, Director, Inter Alia, Taxability, Claims, Interpretation, Receiver, Accrual Of Income, Advance Tax, General Provisions, Maintain, Goods, Period, Consent, Procedure, Board Of Revenue, Payment, International Agreements, Endorsement, Practice, Consideration, Orders, Taxpayer, Tax Treatment, Avoidance Of Double Taxation Result: Order accordingly ORDER [ Munib Akhtar. J.] - By this cortimon judgment, we intend disposing of these 785 Roference Applications, the particulars of wwhich are given in the Appendix, since the Roferences raise common issues with regard to the interpretation of sections 7 and 107 (and other provisions) of the Income Tax Ordinance. 2001 ("2001 Ordinance") and certain double taxation -avoidance agreements entered into by Pakistan. The double taxation agreements ("DTAs")…

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