Section 44D - Special provisions for computing income by way of royalties, etc., in the case of foreign companies

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.