Computation of royalty and technical service fees treated as business profits when effectively connected with a permanent establishment. Income characterized as royalty or fees for technical services received by a specified non-resident shall be computed as Profits and gains of business or profession when received from the Government or an Indian concern under an agreement, the non-resident operates in India through a permanent establishment or fixed place of profession, and the right, property or contract is effectively connected with that establishment or place; specified disallowances apply and prescribed accounting and audit obligations must be complied with.
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.
Computation of royalty and technical service fees treated as business profits when effectively connected with a permanent establishment.
Income characterized as royalty or fees for technical services received by a specified non-resident shall be computed as Profits and gains of business or profession when received from the Government or an Indian concern under an agreement, the non-resident operates in India through a permanent establishment or fixed place of profession, and the right, property or contract is effectively connected with that establishment or place; specified disallowances apply and prescribed accounting and audit obligations must be complied with.
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