BARENDRA PRASAD RAY & ORS. vs THE INCOME TAX OFFICER 'A' WARD FOREIGN SECTION AND ORS.

The Supreme Court held that under Section 163(1) of the Income Tax Act, 1961, the appellants were deemed agents of Mr. Blanco White, a non-resident barrister, due to a business connection established through their engagement in legal proceedings. The Court found that the connection was not casual but substantial, as the appellants had been in correspondence with the London solicitors who engaged Mr. Blanco White, and he earned fees for services rendered in India. The appeal was dismissed, affirming the lower court's ruling that income accrued to Mr. Blanco White in India, thus obligating the appellants to deduct tax at source.