1995 PTD 224 BOMBAY-HIGH-COURT-INDIA

1995  PTD  224     BOMBAY-HIGH-COURT-INDIA

HYUNDAI HEAVY INDUSTRIES COMPANY LIMITED

Versus

D.C. PANT

Income Tax —-Recovery of tax—Garnishee proceedings—Non-resident entering into agreement with Oil and Natural Gas Commission and granting sub-contract to Italian company—Non-resident agreeing to pay taxes levied on Italian company—No contractual relation between Italian company and Oil and Natural Gas Commission—Garnishee proceedings against Oil and Natural Gas Commission on amounts payable to non-resident in respect of tax liability of Italian company–Not valid—Indian Income Tax Act, 1961, S.226(3).