https://www.taxtmi.com/article/detailed?id=16295 Section 44BBD inserts a presumptive taxation regime for non-residents providing services or technology to residents establishing or operating electronics manufacturing facilities in India under a notified scheme. Twenty-five per cent of the aggregate specified amounts is deemed to be business profits chargeable under the head Profits and gains of business or profession. The proviso to Section 44BBD(2) expressly excludes the application of Sections 44DA and 115A to amounts covered by the section, while treaty analysis remains relevant because the deeming fiction applies to profits and not to a Permanent Establishment. en-us Tue, 28 Apr 2026 07:30:28 +0530 Tue, 28 Apr 2026 07:30:28 +0530 TaxTMI RSS Generator https://www.taxtmi.com/article/detailed?id=16295 Section 44BBD inserts a presumptive taxation regime for non-residents providing services or technology to residents establishing or operating electronics manufacturing facilities in India under a notified scheme. Twenty-five per cent of the aggregate specified amounts is deemed to be business profits chargeable under the head Profits and gains of business or profession. The proviso to Section 44BBD(2) expressly excludes the application of Sections 44DA and 115A to amounts covered by the section, while treaty analysis remains relevant because the deeming fiction applies to profits and not to a Permanent Establishment. Articles Income Tax Tue, 28 Apr 2026 07:30:28 +0530 https://www.taxtmi.com/article/detailed?id=16295