Section 44BBD sets 25% presumptive tax on non-resident electronics manufacturing services from April 2026
Section 44BBD provides special computation rules for non-resident entities engaged in providing services or technology for electronics manufacturing facilities in India. The provision applies to non-residents working with resident companies under government-notified schemes in the Ministry of Electronics and Information Technology. Under this presumptive taxation regime, 25% of gross receipts is deemed as taxable profits, regardless of actual profit margins. The computation base includes amounts paid or received for services or technology provision. The section excludes the application of Sections 44DA and 115A, which deal with alternative taxation methods for royalties and technical services. Additionally, it disallows set-off of brought forward losses and unabsorbed depreciation, ensuring taxation on a gross basis. This targeted provision aims to simplify tax compliance for qualifying electronics sector transactions while preventing tax planning through loss adjustments. The measure becomes effective from April 1, 2026.