When a resident can be treated as an agent of a non-resident u/s 163 of IT Act, 1961

RELEVANT PARAGRAPH

5. Rival contentions heard. On a careful consideration of the facts of circumstances of the case and on perusal of the papers on record we hold as follows:

5.2 Here is a case where the foreign company was in receipt of some income from the assessee, on account of sale of shares of Revathi Equipment Ltd. A plain reading of this section leaves no doubt that

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