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11 Section 12(3)(a) & (b) reads as follows:
Any income by way of interest payable by -
(a) a person who is a resident, except where the interest is payable in respect of any
debt incurred, or moneys borrowed and used, for the purposes of a business or profession
carried on by such person outside Pakistan or for the purposes of making or earning any
income from any source outside Pakistan; or
(b) a person who is a non-resident, where the interest is payable in respect of any debt
incurred, or moneys borrowed and used, for the purposes of a business or profession
carried on by such person in Pakistan or for the purposes of making or earning any income
from any source in Pakistan,
shall be deemed to accrue or arise in Pakistan.
