Section 44D
Special provisions for computing income by way of royalties, etc., in the case of foreign companies
Quick Answer
Section 44D (Special provisions for computing income by way of royalties, etc., in the case of foreign companies) has been deleted under the Income-tax Act, 2025, effective 1st April 2026.
What changed for Section 44D
Under the Income Tax Act, 1961, Section 44D governs special provisions for computing income by way of royalties, etc., in the case of foreign companies. Historically governed the computation of royalty and FTS for foreign companies.
Under the Income-tax Act, 2025 (effective 1st April 2026), this provision has been deleted — there is no successor section carrying it forward. NA. Superseded by Section 44DA which brought in the concept of Permanent Establishment (PE) for such computation.
The transition impact on Section 44D is assessed as Medium. Archival value for transfer pricing experts.
Sec 44D
Provision Summary
Historically governed the computation of royalty and FTS for foreign companies.
Deleted
Provision Summary
NA. Superseded by Section 44DA which brought in the concept of Permanent Establishment (PE) for such computation.
Key Changes & Highlights
- Replaced by Section 44DA.
Related Sections
Frequently Asked Questions
Which subject does Section 44D of the 1961 Act cover?
Section 44D of the Income Tax Act, 1961 covers special provisions for computing income by way of royalties, etc., in the case of foreign companies. Historically governed the computation of royalty and FTS for foreign companies.
Is Section 44D of the ITA 1961 still applicable under the Income-tax Act, 2025?
Section 44D has been deleted under the Income-tax Act, 2025, with no successor section carrying it forward from 1st April 2026. NA. Superseded by Section 44DA which brought in the concept of Permanent Establishment (PE) for such computation.
How does the Income-tax Act, 2025 affect Section 44D in practice?
The transition impact for Section 44D is rated Medium. Archival value for transfer pricing experts.
What is new about Section 44D under the Income-tax Act, 2025?
Replaced by Section 44DA. These points are specific to Section 44D (Special provisions for computing income by way of royalties, etc., in the case of foreign companies).
Disclaimer: This mapping of Section 44D (Special provisions for computing income by way of royalties, etc., in the case of foreign companies) under the Income-tax Act, 2025 is for educational and reference purposes only, based on publicly available drafts and circulars. As Section 44D is currently marked Deleted, always confirm its treatment with a qualified Chartered Accountant before filing or making compliance decisions.
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