Even if ‘Representative Assessee’, no liability for unconnected income – Delhi HC

General Electric Company Vs Deputy Director Of Income Tax (Delhi High Court)- Section 163 really provides only the machinery for giving effect to Sections 160 and 161, and the mere appointment of an agent under Section 163 would be of no consequence unless there is income in respect of which the agent can be held to be a representative- assessee under Section 160 and can be assessed as such under Section 161 of the Act. In other words, any person appointed an agent under Section 163 is not necessarily asses-sable as a representative assessee in respect of the non-resident’s income; it is o...