Income Tax Act, 1967.

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Non-residents: restrictions on chargeability.

205.—(1) Nothing in this Chapter shall render a non-resident person chargeable in the name of a broker or general commission agent, or in the name of an agent not being an authorised person carrying on the regular agency of the non-resident person or a person chargeable as if he were an agent in pursuance of the provisions of this Chapter in respect of profits or gains arising from sales or transactions carried out through such a broker or agent.

(2) The fact that a non-resident person executes sales or carries out transactions with other non-residents in circumstances which would make him chargeable in pursuance of the provisions of this Chapter in the name of a resident person shall not of itself make him chargeable in respect of profits arising from those sales or transactions.