https://www.taxtmi.com/caselaws?id=277339 A company could be treated as the agent of non-resident shareholders for income-tax assessment only if the statutory conditions governing receipt of income on their behalf were satisfied. On the facts, the company was not regarded as having received the dividends within that statutory meaning, so the agency fiction did not apply and assessment in respect of the shareholders' dividends failed. As the agency question was answered against the revenue, the connected issue of super-tax liability on that basis did not arise for determination. en-us Tue, 17 Jan 1922 00:00:00 +0530 Sat, 01 Dec 2018 12:51:21 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=277339 A company could be treated as the agent of non-resident shareholders for income-tax assessment only if the statutory conditions governing receipt of income on their behalf were satisfied. On the facts, the company was not regarded as having received the dividends within that statutory meaning, so the agency fiction did not apply and assessment in respect of the shareholders' dividends failed. As the agency question was answered against the revenue, the connected issue of super-tax liability on that basis did not arise for determination. Case-Laws Income Tax Tue, 17 Jan 1922 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=277339