Section 44DA of ITA, 1961 : Section 44Da: Special Provision For Computing Income By Way Of Royalties, Etc, In The Case Of Non- Residents

ITA, 1961

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Explanation using Example

Imagine a Canadian software development company, MapleTech Inc., which enters into an agreement with an Indian government agency on April 10, 2005, to provide a specialized software solution. MapleTech Inc. sets up an office in Bangalore, India, which qualifies as a permanent establishment under Indian tax law. The software developed is used by the Indian government, and in return, MapleTech Inc. receives fees for technical services.

In this scenario, the income received by MapleTech Inc. from the Indian government as fees for technical services is connected to its permanent establishment in Bangalore. A...

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