https://www.taxtmi.com/caselaws?id=181361 A non-resident could be treated as an agent under the income-tax agency provision because the statutory language contained no residence-based restriction; the agency provision only identified the person liable for recovery, while taxability depended on the separate business-connection rule. The dealings between the assessee and the non-resident principals were held to constitute a business connection because repeated supplies during the assessment year, together with the substantial and continuous nature of the transactions, showed continuity rather than a stray arrangement. The Department could proceed against either the principal or the agent in respect of the same income, and the assessment of the agent was sustained, while concurrent assessment of the principal was left open. en-us Fri, 10 Sep 1954 00:00:00 +0530 Thu, 14 Apr 2016 17:38:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=181361 A non-resident could be treated as an agent under the income-tax agency provision because the statutory language contained no residence-based restriction; the agency provision only identified the person liable for recovery, while taxability depended on the separate business-connection rule. The dealings between the assessee and the non-resident principals were held to constitute a business connection because repeated supplies during the assessment year, together with the substantial and continuous nature of the transactions, showed continuity rather than a stray arrangement. The Department could proceed against either the principal or the agent in respect of the same income, and the assessment of the agent was sustained, while concurrent assessment of the principal was left open. Case-Laws Income Tax Fri, 10 Sep 1954 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=181361