Sum paid to NR for import of coal through agent not taxable in India: ITAT

INTERNATIONAL TAXATION: Where assessee imported coal from four non-resident suppliers through common broker, namely 'SPEPL', since there was no role of SPEPL directly or indirectly in respect of sales, coal shipment services, collection of money and import documentation and SPEPL had no authority to conclude contract on behalf of non-resident suppliers nor it had any role leading to conclusion of contracts, case of assessee squarely fell in proviso to section 9(1) and income could not be deemed

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