Agent definition for non-residents clarifies taxable connections and broker exceptions, with a right to be heard. The provision identifies who qualifies as an agent of a non-resident-employees or persons acting on behalf of the non-resident in India, persons with a business connection, persons through whom the non-resident receives income, trustees, and transferees of capital assets in India-and excludes a broker dealing through a non-resident broker when both act in the ordinary course of business; it also requires an opportunity to be heard before treating a person as an agent.
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Provisions expressly mentioned in the judgment/order text.
Agent definition for non-residents clarifies taxable connections and broker exceptions, with a right to be heard.
The provision identifies who qualifies as an agent of a non-resident-employees or persons acting on behalf of the non-resident in India, persons with a business connection, persons through whom the non-resident receives income, trustees, and transferees of capital assets in India-and excludes a broker dealing through a non-resident broker when both act in the ordinary course of business; it also requires an opportunity to be heard before treating a person as an agent.
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