TaxTMI 
TaxTMI 
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. [ Section 44BBD ]
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....g 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. [ Section 44BBD ] [ W.e.f. 01.04.2026 Inserted vide Section 11 of the Finance Act, 2025 ] Applicability and Scope [ Section 44BBD(1) ] * Secti....
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....by the Central Government in the Ministry of Electronics and Information Technology**, * Where the **resident company satisfies prescribed conditions**. * The provision is thus targeted and does not apply to all non-residents or all kinds of services/technology transfers. The transaction must be with a resident company participating in a government-notified scheme, ensuring that the benefit is....
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....nt 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 assessee or on his behalf on account of providing services or technology. * This broad formulation ensures that both actual and constructive receipts, as well as payments made to agents or intermediaries, are covered. ....
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....y past losses or depreciation, thereby simplifying assessment and preventing potential tax planning or manipulation. Important Points to be considered * Potential Issues and Ambiguities identified under this section * The section does not define "services or technology," which may lead to interpretational issues. For instance, whether routine management services or only high-value techn....