https://www.taxtmi.com/caselaws?id=27685 Business connection under the deeming provisions requires a real and intimate link between the non-resident's income-earning operations and activities in India, and income is attributable only to operations carried out in the taxable territory. On the stated facts, contracts were concluded abroad, price and delivery were outside India, and orders sent from India became binding only after acceptance overseas. The Indian company had no authority to accept offers or bind the non-residents, so privity necessary for treating it as their agent was absent. A del credere description did not change that position, because it did not itself confer authority to conclude contracts. en-us Fri, 15 Sep 1972 00:00:00 +0530 Mon, 15 Feb 2010 13:40:38 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=27685 Business connection under the deeming provisions requires a real and intimate link between the non-resident's income-earning operations and activities in India, and income is attributable only to operations carried out in the taxable territory. On the stated facts, contracts were concluded abroad, price and delivery were outside India, and orders sent from India became binding only after acceptance overseas. The Indian company had no authority to accept offers or bind the non-residents, so privity necessary for treating it as their agent was absent. A del credere description did not change that position, because it did not itself confer authority to conclude contracts. Case-Laws Income Tax Fri, 15 Sep 1972 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=27685