"Agent" in relation to a Non-resident

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..... the non-resident; or (c) from or through whom the non-resident is in receipt of any income, whether directly or indirectly; or (d) who is the trustee of the non-resident; and includes also any other person who, whether a resident or non-resident, has acquired by means of a transfer, a capital asset in India : Provided that a broker in India who, in respect of any transactions, does not dea .....

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..... ng heard by the Assessing Officers as to his liability to be treated as such. DCIT MUMBAI Vs KEYSTONE REALTORS PRIVATE LIMITED AS REPRESENTATIVE ASSESSEE OF M/S. MAUSMI VENTURES LTD- 2023 (9) TMI 1205 - ITAT MUMBAI "..........................from conjoint reading of section 163 and section 246(1)(d) of the Act, it is unambiguously clear that before treating any person as agent a separate o .....

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