Any person from whom a non-resident is in receipt of any income can be treated as an agent of such non-resident: Mumbai ITAT

A recent ruling of the Mumbai Income Tax Appellate Tribunal (ITAT) in the case of Hindalco Industries Ltd. (Taxpayer) [AIT ­2010-211-1TAT] under the provisions of the Indian Tax Act, 1961 (ITA), held that any person from whom a non ­resident is in receipt of any income can be treated as an agent of such non-resident.

Such an agent is treated as a representative assessee for the purpose of assessment of income of such non-resident under the ITA. The ITAT held that income which has been assessed to tax in the hands of the non-

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