https://www.taxtmi.com/caselaws?id=59716 The Special Bench concluded that the assessee, who voluntarily filed returns as an agent of the non-resident, was not treated as an agent under section 163. Consequently, the time limit under section 149(3) did not apply. The Bench emphasized that an order under section 163(2) is mandatory to treat a person as an agent of the non-resident, and such an order must precede the issuance of a notice under section 148. The Bench answered the question referred to it in the negative, in favor of the revenue and against the assessee. en-us Thu, 05 Mar 2009 00:00:00 +0530 Wed, 12 Jun 2013 17:12:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=59716 The Special Bench concluded that the assessee, who voluntarily filed returns as an agent of the non-resident, was not treated as an agent under section 163. Consequently, the time limit under section 149(3) did not apply. The Bench emphasized that an order under section 163(2) is mandatory to treat a person as an agent of the non-resident, and such an order must precede the issuance of a notice under section 148. The Bench answered the question referred to it in the negative, in favor of the revenue and against the assessee. Case-Laws Income Tax Thu, 05 Mar 2009 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=59716