Applicability of the amended provisions of section 44D of the Income-tax Act, 1961--Clarification regarding

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..... inance Act, 1976, provides that the deductions admissible in computing the income of a foreign company by way of royalty or fees for technical services received in pursuance of agreements made before April 1, 1976, shall not exceed twenty per cent. of the gross amount of such royalty or fees for technical services as reduced by any lump sum consideration received for transfer outside India of, or .....

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..... purposes of section 195 only. In other words, it is merely intended to regularise any deduction made under that section up to May 31, 1976, in accordance with the earlier provision in this regard. 3. It is, therefore, once again emphasised that the restrictions placed by section 44D apply for the entire previous year relevant to the assessment year 1977-78 and onwards. 4. The above instructio .....

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