Deemed profits for non-residents supplying services or technology to electronics manufacturers become taxable under business income rules. A special computation rule deems a portion of amounts paid or payable and amounts received or deemed received by a non-resident for providing services or technology related to establishing or operating an electronics manufacturing facility for a resident company (participating in a notified government scheme and meeting prescribed conditions) to be the profits and gains of the non-resident's business chargeable to tax under business income provisions; set off of unabsorbed depreciation and brought forward losses is disallowed where profits are declared under this deeming rule.
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.
Deemed profits for non-residents supplying services or technology to electronics manufacturers become taxable under business income rules.
A special computation rule deems a portion of amounts paid or payable and amounts received or deemed received by a non-resident for providing services or technology related to establishing or operating an electronics manufacturing facility for a resident company (participating in a notified government scheme and meeting prescribed conditions) to be the profits and gains of the non-resident's business chargeable to tax under business income provisions; set off of unabsorbed depreciation and brought forward losses is disallowed where profits are declared under this deeming rule.
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