Employer couldn't be held as representative for employee who wasn't holding status of NR in relevant

IT/ILT : In terms of section 163, relevant period to be considered is not date of appointment of statutory agent, but period covering year of account and, thus, where a person in respect of whom agent is sought to be made a representative assessee, does not attain status of non-resident during relevant accounting period, provisions of section 163 cannot be invoked in such a case