Tax on foreign company passive receipts sets specific rates and applies alongside normal tax liability. Sections 115A and 115B create special tax computations by isolating specified heads of income and applying targeted rates, then aggregating those amounts with the tax on the residual income under normal rules. Section 115A targets foreign companies receiving dividends, royalty, and fees for technical services from Indian concerns under post March 1976 agreements (with a transitional exception for deemed earlier agreements). Section 115B targets profits and gains of life insurance business and aggregates tax on those profits with tax on remaining income.
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Provisions expressly mentioned in the judgment/order text.
Tax on foreign company passive receipts sets specific rates and applies alongside normal tax liability.
Sections 115A and 115B create special tax computations by isolating specified heads of income and applying targeted rates, then aggregating those amounts with the tax on the residual income under normal rules. Section 115A targets foreign companies receiving dividends, royalty, and fees for technical services from Indian concerns under post March 1976 agreements (with a transitional exception for deemed earlier agreements). Section 115B targets profits and gains of life insurance business and aggregates tax on those profits with tax on remaining income.
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