Income-tax Act, 1961

Special provision for computing income by way of royalties, etc., in case of non-residents.

44DA. (1) The income by way of royalty or fees for technical services received from Government or an Indian concern in pursuance of an agreement made by a non-resident (not being a company) or a foreign company with Government or the Indian concern after the 31st day of March, 2003, where such non-resident (not being a company) or a foreign company carries on business in India through a permanent establishment situated therein, or performs professional services from a fixed place of profession situated therein, and the right, property or contract in respect of which the royalties or fees for technical services are paid is effectively connected with such permanent establishment or fixed place of profession, as the case may be, shall be computed under the head "Profits and gains of business or profession" in accordance with the provisions of this Act :

Provided that no deduction shall be allowed,-

(i)	-	in respect of any expenditure or allowance which is not wholly and exclusively incurred for the business of such permanent establishment or fixed place of profession in India; or
(ii)	-	in respect of amounts, if any, paid (otherwise than towards reimbursement of actual expenses) by the permanent e .... To read the full section download the app from Google Play store Latest Job Openings View all ARTICLESHIP 18 September 2026 Industrial Trainee Twenty Point Nine Five Ventures Private Limited Noida CA Inter View Details 22 September 2026 Account Assistant Chirag P Shah & Co. Chartered Accountant Pune B.Com View Details ARTICLESHIP 28 September 2026 Junior Accountant J S P M & Associates LLP Pune B.Com View Details ARTICLESHIP 16 September 2026 Article Assistant MANUJ SHARMA AND COMPANY Noida CA Inter View Details 16 September 2026 Internal Audit - Team Lead Consulting & Beyond Chennai CA View Details 09 September 2026 Chartered Accountant Aviv Global Private Limited Ahmedabad CA View Details Featured 11 September 2026 Audit Executive RBSM Corporate Advisors Private Limited Pune CA View Details ARTICLESHIP 30 September 2026 CA Article Assistant CA Suraj Garg & Associates New Delhi CA Final View Details Share  Facebook  Twitter  Linkedin  Reddit  Email  Whatsapp  Gmail  Print  PDF Finance and Tax WhatsApp groups list CCI All Updates (WA Group) CCI All Updates (WA Channel) CCI All Updates (Telegram Channel) GST Income Tax CA Final CA Inter CA Foundation CCI Jobs CS CCI Webinars CCI Pro Login at CAclubindia CAclubindia India's largest network for finance professionals User Name Password Remember Me Forgot Password ? Alternatively, you can log in using: Login with Google Don't have an account? Register Now click here to register Follow Us