PAKISTAN RIVER STEAMERS LTD. vs THE COMMISSIONER OF INCOME-TAX, — 1971 PTD 204

Citation: 1971 PTD 204

Court: Dacca

Year: 1970

Decision Date: 1970-12-31

Parties: PAKISTAN RIVER STEAMERS LTD. vs THE COMMISSIONER OF INCOME-TAX, JUDGMENT

Headnotes

Case cited as 1971 PTD 204

Judgment Text

Court Name: Dacca Judge(s): K. Hossain, B. A. Siddiqi Title:PAKISTAN RIVER STEAMERS LTD. vs THE COMMISSIONER OF INCOME-TAX, JUDGMENT Reported As: 1971 PTD 204 Result: Rule discharged Judgment JUDGMENT K. HOSSAIN, J.-The petitioner, Pakistan River Steamers Ltd. Have challenged in this writ petition the order dated 15-7-61 passed by the Income-tax Officer, Companies Circle Il under section 35 of the Income-tax Act and the order dated 15-6-67 passed by the Commissioner, Income-tax, Dacca Zone rejecting the review petition under section 33-A (2) of the Act. The facts involved in this writ petition are that the petitioner Company is a successor-in-interest of Rivers Steam Navigation Co. Ltd. During the calendar year 1946, being the previous year for the assessment year 1947-49, the predecessor of the Company Rivers Steam Navigation Co. Limited, having its registered Office in the United Kingdom, had business in areas in the then British India. The said company's assessm ent for the year 1947-48, was, however, pending on the date of Independence of India and Pakistan. The same assessm ent was completed in India on 24-3-52 on the status of the company as non-resident. In accordance with article II of the Agreement for the Avoidance of Double Taxation of Income between Pakistan and India, the Company's assessment for the year 1947-48 was, therefore, to be made in Pakistan as well and it was actually so made on 29-3-52 by the then Income-tax Officer, Section II, Com--panies Circle…

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