Section 44DA: Calculate Non-Resident Income from Royalties, Technical Fees; Deduct Expenses, Taxed at Regular Rates
Section 44DA addresses the computation of income from royalties or fees for technical services received by non-residents and foreign companies from the government or Indian entities. This income is calculated on a net basis, allowing for expenses under the Profits and Gains of Business or Profession (PGBP) chapter and taxed at regular rates. It applies when the non-resident operates through a permanent establishment or fixed place of profession in India, with the income effectively connected to this establishment. Deductions are not permitted for expenses not wholly incurred for the business in India or for payments to the head office, except for actual expense reimbursements.