Section 44BBD - 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

Presumptive taxation for non-resident service and technology providers: fixed share of receipts deemed business income; restricted deductions.

Section 44BBD creates a targeted presumptive tax for non-residents supplying services or technology to resident companies under a government-notified electronics manufacturing scheme. A fixed portion of receipts-calculated as 25% of specified amounts paid, payable, received or deemed received-is deemed business income. The rule operates notwithstanding general business computation provisions, excludes application of alternate non-resident tax concessions to those amounts, and precludes set-off of unabsorbed depreciation and brought forward business losses in the year the presumptive computation is chosen.