Presumptive Taxation for Non-Residents in India: Clause 61 of the Income Tax Bill, 2025 merging Sections 44B, 44BB, 44BBA, 44BBB, 44BBC and 44BBD of Income Tax Act, 1961

Presumptive taxation for non-residents fixes sectoral deemed profit rates and permits audit-based lower profit declaration.

Clause 61 establishes a special presumptive computation regime for specified non-resident business activities-shipping (including demurrage), cruise ships, aircraft operation, turnkey power project construction, mineral-oil services, and specified electronics services-by prescribing sectoral deemed profit rates as the taxable base, permitting non-residents to elect audit-based lower declared profits if they maintain detailed books and undergo audit, and restricting allowance of losses, deductions, and depreciation against the presumptively computed income.