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of <h1>Section 163 defines agent of non-resident including employees trustees and asset transferees with hearing rights</h1> Section 163 of the Income Tax Act, 1961 defines who may be regarded as an agent of a non-resident for tax purposes. An agent includes any person in India who is employed by the non-resident, has business connections with them, receives income from them directly or indirectly, or serves as their trustee. The provision also covers persons who acquire capital assets in India through transfers. However, brokers dealing through non-resident brokers rather than directly with non-resident principals are excluded from agent status under specific conditions. No person can be treated as an agent without being given an opportunity to be heard by the Assessing Officer regarding their liability.
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