Chapter XII-DASPECIAL PROVISIONS RELATING TO TAX ON DISTRIBUTED INCOME OF DOMESTIC COMPANY FOR BUY-BACK OF SHARES (From Section 115QA to Section 115QC )
Part CProcedure for filing of return in respect of fringe benefits, assessment and payment of tax in respect thereof (From Section 115WD to Section 115WM )
Chapter XX-BREQUIREMENT AS TO MODE OF ACCEPTANCE, PAYMENT OR REPAYMENT IN CERTAIN CASES TO COUNTERACT EVASION OF TAX (From Section 269SS to Section 269TT )
Royalty and technical fees taxation: treat connected receipts as business profits with restricted deductions and audit obligations. Income by way of royalty or fees for technical services received from Government or an Indian concern by a non-resident or foreign company is to be ... Summary
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Royalty and technical fees taxation: treat connected receipts as business profits with restricted deductions and audit obligations.
Income by way of royalty or fees for technical services received from Government or an Indian concern by a non-resident or foreign company is to be computed under Profits and gains of business or profession where the non-resident carries on business in India through a permanent establishment or performs services from a fixed place in India and the right, property or contract is effectively connected with that establishment; deductions not wholly and exclusively incurred for the Indian establishment and amounts remitted to head office (other than reimbursements) are disallowed.
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