COMMISSIONER INLAND REVENUE Z-III, CORPORATE REGIONAL TAX OFFICE, TAX HOUSE, KARACHI vs MSC SWITZERLAND GENEVA Ss — 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 Ss
Subject matter: Criminal

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 Ss. 4B, 44(1), 107(1) & 109---Constitution of Pakistan, Art. 188---Review petition---Non-resident companies---Super tax, imposition of---Double Taxation Treaties---Convention between the Islamic Republic of Pakistan and the Swiss Confederation for the Avoidance of Double Taxation with respect to Taxes on Income ("Swiss DTT"), Art. 2---Held, that High Court considered the pros and cons of the entire controversy and the questions of law raised and thereafter reached to the analytical conclusion that the levy of Super Tax was identical to the levies that existed at the time the treaties in question came into force, hence the tax-payers within the realm of double taxation treaties are either exempt or, wherever applicable, liable to pay the Super Tax at reduced rates in terms of their respective treaties---No justification or rationale existed to entertain and consider the present review petitions when the High Court had extensively considered all the questions raised before it and comprehensibly discussed the pros and cons and passed a reasonable consolidated judgment which did not warrant any interference and was therefore affirmed by the Supreme Court through the order under review---Review petitions were dismissed accordingly.

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