Non-Residents—Income Accruing or Arising through or from Business connection in India—Liability to Tax—Section 9 of the Income-tax Act, 1961

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....9 of the Income-tax Act, 1961. Attention is invited to para. 3(7) of Board's Public Circular No. 23 of 1969 dated 23rd July, 1969, wherein it has been stated as follows : " Where, however, there is a regular agency established in India for purchase of the entire raw materials required for the purpose of manufacture and sale abroad and the agent is chosen by reason of his skill, rep....

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.... from operations which are confined to purchase of goods in India for the purpose of export. Accordingly, the mere existence of an agency established by a non-resident in India will not be sufficient to make the non-resident liable to tax, if the sole function of the agency is to purchase goods for export. This legal position has also been explained in para. 3(5) of the Board's Public Circular....