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 Featured ARTICLESHIP 19 March 2026 Article Assistant Gupta Sachdeva & Co. Chartered Accountants New Delhi CA Final View Details Featured 28 March 2026 Accountant Ashok Amol & Associates New Delhi B.Com View Details Featured 29 April 2026 Manager- Finance and Compliance Naveen Fintech Pvt Ltd Kolkata CA Inter View Details Featured 13 April 2026 GST CONSULTANCY Abhishek G Agrawal & Co. Korba CA Final View Details Featured 14 April 2026 GST CONSULTANT Abhishek G Agrawal & Co. Korba CA Final View Details Featured 28 March 2026 CA Final Ashok Amol & Associates New Delhi CA Final View Details Share  Facebook  Twitter  Linkedin  Reddit  Email  Whatsapp  Gmail  Pocket  Print  Pinterest  PDF  Translate Whatsapp Groups GST Income Tax CA Final CA Inter CAclubindia 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