https://www.taxtmi.com/caselaws?id=207180 The tribunal held that M/s. BSAMC was rightly treated as an agent of non-resident investors under section 163 of the Income-tax Act, 1961. The tribunal clarified that parallel proceedings under sections 201 and 163 can coexist as they serve different purposes within the taxation scheme. Additionally, the tribunal affirmed that the taxability of capital gains under the Double Tax Avoidance Agreement with UAE remains unaffected by the agent status of M/s. BSAMC. The distinction between an assessee and a person under the Act was explained, emphasizing that M/s. BSAMC's role as a payer does not automatically make it liable for non-residents' tax obligations. en-us Tue, 23 Feb 2010 00:00:00 +0530 Tue, 14 Aug 2012 12:15:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=207180 The tribunal held that M/s. BSAMC was rightly treated as an agent of non-resident investors under section 163 of the Income-tax Act, 1961. The tribunal clarified that parallel proceedings under sections 201 and 163 can coexist as they serve different purposes within the taxation scheme. Additionally, the tribunal affirmed that the taxability of capital gains under the Double Tax Avoidance Agreement with UAE remains unaffected by the agent status of M/s. BSAMC. The distinction between an assessee and a person under the Act was explained, emphasizing that M/s. BSAMC's role as a payer does not automatically make it liable for non-residents' tax obligations. Case-Laws Income Tax Tue, 23 Feb 2010 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=207180