COMMISSIONER OF INCOME TAX, CALCUTFA vs T.I. & M. SALES LTD.

The Supreme Court upheld the High Court's decision that the Indian assessee had no business connections with the non-resident companies under Section 9 of the Income Tax Act, 1961. The Court clarified that for liability under Section 163(1)(b), a clear business connection must exist, which was not established in this case. The Court dismissed the Revenue's appeals, affirming that without a relationship under Section 163(1)(a), there is no liability for assessment.