Assessee, a trader in coal, imported coal from four non-resident-suppliers through common broker, namely, ‘SPEPL’, but no tax was deducted at source under S. 195 on payment made to them .AO held that import of coal via broker constituted business connection of non-resident supplier in India and, accordingly, estimated 10 per cent income on alleged purchases from non-resident sellers as taxable income in India . CIT (A) confirmed the addition. On appeal the Tribunal held that  non-resident suppliers directly delivered coal from outside India to assessee without routing through agent SPEPL and there was no role of SPEPL directly or indirectly in respect of sales, coal shipment services, collection of money and import documentation and SPEPL had no authority to conclude contract on behalf of non-resident suppliers. Since no business connection was established, income cannot be deemed to have accrued or arose in India in transaction of export of coal to assessee in India. Not liable to deduct tax at source . (AY. 2015 -16)