https://www.taxtmi.com/caselaws?id=36174 Interest income from money lent for deployment in Pakistan fell within item 5(f) of the Indo-Pakistan double taxation agreement because the decisive factor was the intended and actual bringing of the funds into Pakistan for that specific business purpose. Although the lending transaction occurred in Calcutta, the advances were meant for the management and development of sugar mills in East Pakistan, and the funds were in fact taken there for that purpose. Item 9, being residuary, did not apply where item 5(f) directly covered the income. The question was answered in favour of the assessee. en-us Fri, 10 Mar 1978 00:00:00 +0530 Fri, 19 Mar 2010 17:32:56 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=36174 Interest income from money lent for deployment in Pakistan fell within item 5(f) of the Indo-Pakistan double taxation agreement because the decisive factor was the intended and actual bringing of the funds into Pakistan for that specific business purpose. Although the lending transaction occurred in Calcutta, the advances were meant for the management and development of sugar mills in East Pakistan, and the funds were in fact taken there for that purpose. Item 9, being residuary, did not apply where item 5(f) directly covered the income. The question was answered in favour of the assessee. Case-Laws Income Tax Fri, 10 Mar 1978 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=36174