Section 44BBD - Special provision for computing profits and gains of non-residents engaged in business of providing services or technology for setting up an electronics manufacturing facility or in connection with manufacturing or producing electronic goods, article or thing in India

25% of payments to non-resident for EM manufacturing services deemed taxable profits; Sections 44DA and 115A excluded

Where a non-resident provides services or technology in India for establishing or supporting an electronics manufacturing facility to a resident company operating under a government-notified scheme and meeting prescribed conditions, 25% of the aggregate amounts paid or payable and received or deemed received for those services/technology shall be deemed the non-resident's taxable profits under 'profits and gains of business or profession.' Sections 44DA and 115A do not apply to those amounts, and no set-off of unabsorbed depreciation or brought-forward losses is permitted for the relevant previous year.