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of <h1>Non-residents not taxed on profits from purchasing raw materials in India for export u/s 9.</h1> The circular clarifies the tax liability for non-residents under Section 9 of the Income-tax Act, 1961, concerning income accruing from business connections in India. It addresses potential misconceptions from a previous circular, stating that non-residents are not liable for tax on profits from purchasing raw materials in India solely for export, even if done through an established agency. The circular emphasizes that the mere presence of such an agency does not constitute a taxable business connection, as long as its sole function is purchasing goods for export, in line with the exemption in clause (b) of the Explanation to section 9(1)(i).
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