INTER QUEST INFORMATICS SERVICES vs The COMMISSIONER OF INCOME TAX Ss — 2025 SCMR 257 SUPREME-COURT

Case information

Citation: 2025 SCMR 257 SUPREME-COURT
Court: Supreme Court of Pakistan
Year: 2025
Reporter: SCMR
Parties: INTER QUEST INFORMATICS SERVICES vs The COMMISSIONER OF INCOME TAX Ss
Subject matter: Tax & Customs
Provisions referred to: Income Tax Ordinance (XXXI of 1979)

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

INTER QUEST INFORMATICS SERVICES VS The COMMISSIONER OF INCOME TAX Ss. 107 & 133(1)---Income Tax Ordinance (XXXI of 1979) (since repealed), Ss. 163 & 136(1)---Convention Between the Kingdom of the Netherlands and the Islamic Republic of Pakistan for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income, 1982, Arts. 7, 12, paras. 3(a), 3(b), 22, 23 & 24---Concept of "Royalties"---Scope---Business profits---Non-resident foreign company---Exemption from income tax---Income/royalties earned by the non-resident company in Pakistan for the lease of certain software---Whether such income was business profits and thus exempt from payment of income tax in Pakistan under Article 7 of the Convention Between the Kingdom of the Netherlands and the Islamic Republic of Pakistan for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income ('the Convention'), or the same constituted "royalties" as defined in paragraph 3 of Article 12 of the Convention and was liable to tax.

Other judgments reported in 2025 SCMR

2025 SCMR 1591 SUPREME-COURTMUHAMMAD IJAZ VS State S. 302(b)---Qatl-i-amd---Re-appraisal of evidence---Absconsion of accused---Not participating in funeral of wife---Ac…
2025 SCMR 1591 SUPREME-COURTMUHAMMAD IJAZ VS State S. 302(b)---Qatl-i-amd---Re-appraisal of evidence---Promptly lodgment of FIR---Accused was alleged to have committed…
2025 SCMR 1742 SUPREME-COURTMUHAMMAD RAMZAN VS State Ss. 302(b) & 398---Qatl-i-amd, attempting to commit robbery or dacoity, when the offender is armed with a deadly we…
2025 SCMR 1730 SUPREME-COURTFARMAN ALI VS State Benefit of doubt---Principle---Prosecution is bound to prove its case beyond the shadow of any slightest doubt and the b…
2025 SCMR 1580 SUPREME-COURTMUHAMMAD BILAL VS State S. 302(b)---Qatl-i-amd---Re-appraisal of evidence---Medical evidence not supporting the ocular account---Accused was…
2025 SCMR 1558 SUPREME-COURTOBAIDULLAH VS State Circumstantial evidence---Scope---In case of circumstantial evidence, every circumstance should be linked with each othe…

Back to the case-law library · Search Pakistani case law in Urdu or English