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of <h1>Special computation for foreign companies: deductions under sections 28-44C capped at 20% for pre-1976 royalties/technical fees</h1> For foreign companies, income from royalties or fees for technical services received from the government or an Indian concern under agreements made before 1 April 1976 is subject to special computation: deductions under sections 28-44C are capped at 20% of the gross royalty/fees after excluding lump-sum consideration for transfers or imparting of information outside India. No deductions under those sections are allowed for such royalties or technical fees received after 31 March 1976 but before 1 April 2003. Definitions of 'fees for technical services,' 'royalty,' and 'foreign company' are as provided elsewhere in the Act, and certain deeming rules apply.
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