Business connection arises when an agent concludes contracts or maintains stock, making attributable income Indian-sourced. A business connection exists where a person in India acting for a non-resident has authority to conclude contracts (other than authority limited to purchasing goods), habitually maintains stock for regular deliveries on behalf of the non-resident, or habitually secures orders in India mainly or wholly for the non-resident. Independent brokers or commission agents acting in the ordinary course and not working mainly or wholly for the non-resident are excluded. Only income attributable to that business connection is treated as income accruing or arising from India.