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 the order of the Assessing Officer cannot be faulted with. The Act uses the words “from or through” instead of the word “through” in section 163(1)(c) of the Income-tax Act, 1922. Any person from or ...