https://www.taxtmi.com/caselaws?id=6015 Income derived from money lent at interest and brought into Pakistan for the purposes of managed companies fell within the specific scope of clause 5(f) of the India and Pakistan Avoidance of Double Taxation Agreement. Clause 9 was only a residuary provision and could not displace a case expressly covered by clause 5(f). The Supreme Court affirmed the High Court's view, so the receipt was treated under the specific treaty provision and the answer was against the Revenue and in favour of the assessee. en-us Tue, 28 Jan 1997 00:00:00 +0530 Sun, 30 Nov 2008 00:00:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=6015 Income derived from money lent at interest and brought into Pakistan for the purposes of managed companies fell within the specific scope of clause 5(f) of the India and Pakistan Avoidance of Double Taxation Agreement. Clause 9 was only a residuary provision and could not displace a case expressly covered by clause 5(f). The Supreme Court affirmed the High Court's view, so the receipt was treated under the specific treaty provision and the answer was against the Revenue and in favour of the assessee. Case-Laws Income Tax Tue, 28 Jan 1997 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=6015