https://www.taxtmi.com/caselaws?id=24682 Where the agreement and surrounding facts did not establish a business connection between the non-resident companies and the Indian company, the Indian company could not be treated as their agent under section 163 of the Income-tax Act, 1961, and the assessee succeeded on that issue. The Tribunal's finding that there was no business connection was also not shown to be vitiated by reliance on irrelevant material or by ignoring relevant evidence, so the assessment cancellation was left undisturbed. The Calcutta HC followed its earlier decision on the same assessee and found no independent ground to reach a different conclusion. en-us Wed, 19 Mar 1986 00:00:00 +0530 Thu, 21 Jan 2010 16:27:32 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=24682 Where the agreement and surrounding facts did not establish a business connection between the non-resident companies and the Indian company, the Indian company could not be treated as their agent under section 163 of the Income-tax Act, 1961, and the assessee succeeded on that issue. The Tribunal's finding that there was no business connection was also not shown to be vitiated by reliance on irrelevant material or by ignoring relevant evidence, so the assessment cancellation was left undisturbed. The Calcutta HC followed its earlier decision on the same assessee and found no independent ground to reach a different conclusion. Case-Laws Income Tax Wed, 19 Mar 1986 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=24682