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 - (New) Section 61(2)(Table Sl. No. 6) / (Old) Section 44BBD

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

.... of sections 26 to 54, to the extent contrary to this section, shall not apply to the manner of computation of profits and gains of the specified business in section 61(2). Eligibility -  A Non Resident engaged in providing services or technology in India, for the purposes of setting up an electronics manufacturing facility or in connection with manufacturing or producing electronic goods, article or thing in India to a resident company Taxable -  the profits and gains of such business of such assessee chargeable to tax for the said tax year under the head "Profits and gains of business or profession". Manner of Computation of Deemed Profit Taxable Income - 25% of (A+B), where,-- ....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....o in rule 45(1), including their supply chain ecosystem. Exception [ Section 61(9) ] The provisions of sections 59 and 207 shall not apply to amounts referred to in section 61(2) (Table: Sl. No. 6). Under Section 44BBD of the Income Tax Act, 1961 [ Upto 31.03.2026 ] W.e.f. 01.04.2026 Inserted vide Section 11 of the Finance Act, 2025  Special provision for computing profits and gains of 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. Applicability and Scope [ Section 44BBD(1) ] • Section 44BBD commences wi....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....e amounts specified in sub-section (2) will be deemed to be the profits and gains of such business, chargeable under the head "Profits and gains of business or profession". • This means that, irrespective of the actual profit margin, 25% of the gross receipts (as defined) is treated as taxable income in India. Definition of "Amounts" [ Section 44BBD(2) ] • Sub-section (2) defines the "amounts" on which the 25% presumptive rate is to be applied: • (a) The amount paid or payable to the non-resident assessee or to any person on his behalf on account of providing services or technology; and  • (b) The amount received or deemed to be received by the non-resident asse....