https://www.taxtmi.com/caselaws?id=178980 Business connection under section 42(1) of the Income-tax Act, 1922 was treated as a broad factual inquiry, to be determined from the whole arrangement between the non-resident and the Indian company. The court noted that the Indian company acted as exclusive authorised agent in India, earned commission and advertising allowance, had to use that allowance only for the assessee's products, and could not deal in competing products. It rejected the approach of isolating the Indian company's purchasing capacity or treating direct sales separately from the integrated marketing channel. On that totality, a business connection in the taxable territories was found to exist. en-us Mon, 27 Oct 1958 00:00:00 +0530 Wed, 17 Feb 2016 12:57:25 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=178980 Business connection under section 42(1) of the Income-tax Act, 1922 was treated as a broad factual inquiry, to be determined from the whole arrangement between the non-resident and the Indian company. The court noted that the Indian company acted as exclusive authorised agent in India, earned commission and advertising allowance, had to use that allowance only for the assessee's products, and could not deal in competing products. It rejected the approach of isolating the Indian company's purchasing capacity or treating direct sales separately from the integrated marketing channel. On that totality, a business connection in the taxable territories was found to exist. Case-Laws Income Tax Mon, 27 Oct 1958 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=178980