https://www.taxtmi.com/caselaws?id=786712 Assessee not an agent of a non-resident where sale deeds and accounts show the disputed units fell to the assessee's share and consideration was paid to and reported by the assessee; the statutory test for agency requires a non-resident to receive income from or through the alleged agent, which was absent here. Partnership income is received by the partnership and apportioned to partners, not received through the assessee, and no agreement or business connection established agency. Consequently the addition invoking section 163(1)(c) was held unsustainable and deleted. en-us Wed, 21 Jan 2026 00:00:00 +0530 Wed, 18 Feb 2026 08:11:57 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=786712 Assessee not an agent of a non-resident where sale deeds and accounts show the disputed units fell to the assessee's share and consideration was paid to and reported by the assessee; the statutory test for agency requires a non-resident to receive income from or through the alleged agent, which was absent here. Partnership income is received by the partnership and apportioned to partners, not received through the assessee, and no agreement or business connection established agency. Consequently the addition invoking section 163(1)(c) was held unsustainable and deleted. Case-Laws Income Tax Wed, 21 Jan 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=786712