Chapter XII-DA - SPECIAL PROVISIONS RELATING TO TAX ON DISTRIBUTED INCOME OF DOMESTIC COMPANY FOR BUY-BACK OF SHARES (From Section 115QA to Section 115QC)
Part C - Procedure 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-B - REQUIREMENT 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 service income: foreign companies face restricted deduction entitlement for post enactment receipts under special computation rules. Special computation rules require that, for a foreign company, deductions under general business provisions for royalties or fees for technical services received under pre cut off agreements are capped in the aggregate at twenty per cent of the gross amounts after excluding lump sum consideration for transfers or imparting of information outside India; for receipts after the cut off and before a later statutory date, no such deductions are allowed. The section also defines key terms and contains a deeming provision treating certain post cut off receipts as arising under pre cut off agreements for specified purposes.
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.
Provisions expressly mentioned in the judgment/order text.
Royalty and technical service income: foreign companies face restricted deduction entitlement for post enactment receipts under special computation rules.
Special computation rules require that, for a foreign company, deductions under general business provisions for royalties or fees for technical services received under pre cut off agreements are capped in the aggregate at twenty per cent of the gross amounts after excluding lump sum consideration for transfers or imparting of information outside India; for receipts after the cut off and before a later statutory date, no such deductions are allowed. The section also defines key terms and contains a deeming provision treating certain post cut off receipts as arising under pre cut off agreements for specified purposes.
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