Royalty and technical service income computed on a net basis when connected to a permanent establishment, limiting deductible payments. Income of non-residents and foreign companies by way of royalties or fees for technical services is computed on a net income basis when connected to a permanent establishment or fixed place of profession in India; deductions are limited to expenditures wholly and exclusively incurred for that establishment, and payments to head office or other offices are disallowed except reimbursements of actual expenses.
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.
Royalty and technical service income computed on a net basis when connected to a permanent establishment, limiting deductible payments.
Income of non-residents and foreign companies by way of royalties or fees for technical services is computed on a net income basis when connected to a permanent establishment or fixed place of profession in India; deductions are limited to expenditures wholly and exclusively incurred for that establishment, and payments to head office or other offices are disallowed except reimbursements of actual expenses.
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