The foreign company was in receipt of some income from the assessee, on account of sale of shares. The Act uses the words “from or through”, instead of the word ‘thorough’ in s.163(1)(c). Any person in India from or through whom the non-resident is in receipt of any income directly or indirectly can be treated as agent of the non-resident.
Utkal Investments Ltd. v Asst. DIT (2009) 120 TTJ 67 /123 TTJ 286 (Mum).
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