79.  Income from transactions with non-residents.-

Where business is carried on between a resident and a non-resident and it appears to the Deputy Commissioner that conditions are made or imposed between them in their commercial or financial transactions which differ from those which would be made between independent persons, the Deputy Commissioner shall determine the amount of profits which would have accrued to the resident but, by reason of those conditions, have not so accrued, and include such amount in the total income of the resident.