https://www.taxtmi.com/caselaws?id=175605 Section 42 fastened tax liability on profits or gains accruing to a non-resident through a business connection, while Section 43 operated only as machinery to appoint a statutory agent for assessment of income already chargeable under Section 42. The expression "business connection" required a continuing commercial relationship and not a single isolated transaction. On the facts, the agreement was not an outright sale but a licence arrangement with continuing obligations on both sides and the non-resident's entitlement to a share of takings. The assessee was therefore properly treated as agent of the non-resident company, and the profits were chargeable through that business connection. en-us Wed, 02 Nov 1938 00:00:00 +0530 Sat, 28 Nov 2015 12:48:11 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=175605 Section 42 fastened tax liability on profits or gains accruing to a non-resident through a business connection, while Section 43 operated only as machinery to appoint a statutory agent for assessment of income already chargeable under Section 42. The expression "business connection" required a continuing commercial relationship and not a single isolated transaction. On the facts, the agreement was not an outright sale but a licence arrangement with continuing obligations on both sides and the non-resident's entitlement to a share of takings. The assessee was therefore properly treated as agent of the non-resident company, and the profits were chargeable through that business connection. Case-Laws Income Tax Wed, 02 Nov 1938 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=175605