COMMISSIONER INLAND REVENUE Z-III, CORPORATE REGIONAL TAX OFFICE, TAX HOUSE, KARACHI vs MSC SWITZERLAND GENEVA S — 2023 SCMR 1011 SUPREME-COURT

Case information

Citation: 2023 SCMR 1011 SUPREME-COURT
Court: Supreme Court of Pakistan
Year: 2023
Reporter: SCMR
Parties: COMMISSIONER INLAND REVENUE Z-III, CORPORATE REGIONAL TAX OFFICE, TAX HOUSE, KARACHI vs MSC SWITZERLAND GENEVA S
Provisions referred to: S. 107---

Fields are extracted from the reported citation and judgment text. Where a detail is not stated in the record, it is not shown.

Judgment text as reported

COMMISSIONER INLAND REVENUE Z-III, CORPORATE REGIONAL TAX OFFICE, TAX HOUSE, KARACHI VS MSC SWITZERLAND GENEVA S. 107--- avoidance of Double Taxation Treaties (DTT(s)), interpretation of---When any definite and unambiguous stipulation is assimilated in the Double Taxation avoidance treaty or agreement, said provision will obviously supplant and supersede the general provisions encompassed under Tax Laws---However, the fact remains that the foremost purposefulness of a DTT is required to be explored in the background of ministering commercial relations between treaty partners and as being essentially a bargain between the two signatories thereof as to the division of tax revenues between them in respect of income falling to be taxed in both jurisdictions.

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