Canvassing agent not business connection , Non-Resident, even with ‘business connection’, can be taxed only in respect of business operations carried out in India

ADIT Vs Star Cruise India Travel Services (ITAT Mumbai)- In the case of a business of which all the operations are not carried out in India, the income of the business deemed under this clause to accrue or arise in India shall be only such part of the income as is reasonably attributable to the operations carried out in India” but then since no part of the operations was carried out in India, no part of assessee’s income could have been thus taxable in India. It would thus seem to us that when no business operations are carried out in India, even if a non resident has a business connectio...