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of <h1>Tax Relief for Non-Residents: Section 44BBD Sets 25% Deemed Profit Rate on Electronics Manufacturing Services in India</h1> The Finance Act, 2025 inserts section 44BBD into the Income-tax Act, effective April 1, 2026, creating special provisions for non-resident businesses providing services or technology for electronics manufacturing in India. Non-residents supplying such services to qualifying resident companies under government-notified schemes will have 25% of their receipts deemed as taxable business profits. This applies to amounts paid or payable to the non-resident for providing services or technology. The provision explicitly excludes application of sections 44DA and 115A to these transactions, and prohibits set-off of unabsorbed depreciation or brought forward losses when profits are declared under this section.
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