https://www.taxtmi.com/caselaws?id=38942 A non-resident company's sales to its Indian subsidiary were treated as principal-to-principal transactions at arm's length where the contracts were concluded outside India, the goods moved on CIF terms without reservation of disposal, and the subsidiary resold the goods on its own account and paid tax on its own profits. On those findings, the subsidiary was not an agent of the parent, so no part of the non-resident's income was deemed to accrue or arise in India under section 42(3) of the Indian Income-tax Act, 1922. The question of chargeability to tax in India was answered against the Revenue. en-us Wed, 13 Aug 1975 00:00:00 +0530 Sat, 10 Apr 2010 14:11:49 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=38942 A non-resident company's sales to its Indian subsidiary were treated as principal-to-principal transactions at arm's length where the contracts were concluded outside India, the goods moved on CIF terms without reservation of disposal, and the subsidiary resold the goods on its own account and paid tax on its own profits. On those findings, the subsidiary was not an agent of the parent, so no part of the non-resident's income was deemed to accrue or arise in India under section 42(3) of the Indian Income-tax Act, 1922. The question of chargeability to tax in India was answered against the Revenue. Case-Laws Income Tax Wed, 13 Aug 1975 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=38942