Section 44BBB → Section 59
Special provision for computing profits and gains of foreign companies engaged in the business of civil construction, etc., in certain turnkey power projects
Quick Answer
Section 44BBB of the Income Tax Act, 1961 (Special provision for computing profits and gains of foreign companies engaged in the business of civil construction, etc., in certain turnkey power projects) corresponds to Section 59 of the Income-tax Act, 2025, effective 1st April 2026. Status: Retained.
What changed for Section 44BBB
Under the Income Tax Act, 1961, Section 44BBB governs special provision for computing profits and gains of foreign companies engaged in the business of civil construction, etc., in certain turnkey power projects. Presumptive taxation where 10% of the gross receipts of a foreign company executing turnkey power projects in India is deemed as profit.
From 1st April 2026, the same subject sits at Section 59 of the Income-tax Act, 2025 — retained and renumbered as Section 59 of the Income-tax Act, 2025. Retained. Eases compliance for foreign infrastructure contractors.
For Section 44BBB, the practical impact is rated Medium. Important for international infrastructure joint ventures.
Sec 44BBB
Provision Summary
Presumptive taxation where 10% of the gross receipts of a foreign company executing turnkey power projects in India is deemed as profit.
Sec 59
Provision Summary
Retained. Eases compliance for foreign infrastructure contractors.
Key Changes & Highlights
- Allows the assessee to claim lower profits if they maintain regular books of accounts under Section 44AA.
Frequently Asked Questions
What is Section 44BBB of the Income Tax Act, 1961 about?
Section 44BBB of the Income Tax Act, 1961 covers special provision for computing profits and gains of foreign companies engaged in the business of civil construction, etc., in certain turnkey power projects. Presumptive taxation where 10% of the gross receipts of a foreign company executing turnkey power projects in India is deemed as profit.
Which section replaces Section 44BBB in the Income-tax Act, 2025?
Section 44BBB of the Income Tax Act, 1961 maps to Section 59 of the Income-tax Act, 2025, effective 1st April 2026 (status: Retained). Retained. Eases compliance for foreign infrastructure contractors.
What is the impact of the change to Section 44BBB under the new tax code?
The transition impact for Section 44BBB is rated Medium. Important for international infrastructure joint ventures.
What should I watch out for when Section 44BBB moves to the 2025 code?
Allows the assessee to claim lower profits if they maintain regular books of accounts under Section 44AA. These points are specific to Section 44BBB (Special provision for computing profits and gains of foreign companies engaged in the business of civil construction, etc., in certain turnkey power projects).
Disclaimer: This mapping of Section 44BBB (Special provision for computing profits and gains of foreign companies engaged in the business of civil construction, etc., in certain turnkey power projects) to Section 59 of the Income-tax Act, 2025 is for educational and reference purposes only, based on publicly available drafts and circulars. As Section 44BBB is currently marked Retained, always confirm its treatment with a qualified Chartered Accountant before filing or making compliance decisions.
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