Royalty and fees for technical services taxation for non-residents hinges on permanent establishment connection and restricted deductions. Royalty and fees for technical services received by a non-resident or foreign company are taxed under Profits and Gains of Business or Profession where the income is from the Government or an Indian concern, arises under an agreement, the assessee has a permanent establishment or fixed place of profession in India, and the right, property or contract is effectively connected with that establishment. Deductions are limited to expenditure wholly and exclusively incurred for that Indian business, and head office payments other than reimbursement of actual expenses are disallowed. Books, audit, and prescribed reporting requirements also apply.