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12 The concepts of "business connection" under the Ordinance and of permanent establishment or fixed base under the double taxation agreements are almost alike. A business connection involves a relation between a business carried on by a non-resident which yields profits or gains and some activity in Pakistan which contributes directly or indirectly of earning of those profits or gains - CIT v. R.D. Aggarwal & Co. [1965] 56 ITR 20 (SC). Similar to the business/professional presence of a foreign enterprise in Pakistan termed as permanent establishment or fixed base.
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