Notification No. 46/2015 [F. No. 200/17/2014-ITA-I] / SO 1631(E)

What it does

In exercise of the power under clause (6C) of section 10 of the Income-tax Act, 1961, the Central Government declares that any income arising to M/s. Dassault Aviation S.A. by way of royalty or fees for technical services, received in pursuance of General Contract No. Air HQ/96102/2/ASR-DA dated 29 July 2011 entered into between Dassault Aviation and Thales Systemes Aeroportes and the Government of India for undertaking the retrofitting of fifty-one defence aircraft connected with the security of India, shall not be included in computing the total income of a previous year of that company.

Who it reaches

M/s. Dassault Aviation S.A.
The Government of India as payer under the contract
Officers deducting tax on payments of royalty or fees for technical services under the contract
Assessing Officers of the foreign company

The provisions it speaks to

Left, the provision of the Income-tax Act, 1961 as the instrument itself names it. Right, the section of the Income-tax Act, 2025 that the department’s own concordance maps it to — which is where the same ground is now covered.

Under the 1961 Act	Now
s.10	s.11, s.19

The instrument, as the Board published it

The department publishes this one only as a PDF, so the words below were read out of that PDF by machine. That reading can carry its own mistakes — a misread number, a broken line. Check the signed document before you rely on a figure in it.

2 THE GAZETTE OF INDIA : EXTRAORDINARY [PART II—SEC. 3(ii)]

MINISTRY OF FINANCE
(Department of Revenue)
(CENTRAL BOARD OF DIRECT TAXES)
NOTIFICATION

New Delhi, the 17th June, 2015

No. 46/2015-Income-tax

S.O. 1631(E).—In exercise of powers conferred by clause (6C) of section 10 of the Income –tax Act, 1961 (43 of 1961), the Central Government hereby declares that any income arising to M/s. Dassault Aviation S.A., having its office at S.A. au capital de 81 007 176 Euros RCS Paris B 712 042 456, by way of royalty or fees for technical services received in pursuance of the agreement vide General Contract No. Air HQ/96102/2/ASR-DA, on dated 29th July, 2011 entered into between M/s. Dassault Aviation and Thales Systemes Aeroportes and the Government of India for undertaking retrofitting of fifty-one defence aircraft connected with Security of India, shall not be included in computing the total income of a previous year of the said company under the said Act.

[F. No. 200/17/2014-ITA-I]

DEEPSHIKHA SHARMA, Director

Printed by the Manager, Government of India Press, Ring Road, Mayapuri, New Delhi-110064 and Published by the Controller of Publications, Delhi-110054.

From when

17 June 2015.

What to watch

The notification is dated 17 June 2015 and states no separate commencement date or period of years.
The exemption is confined to income by way of royalty or fees for technical services and only that received in pursuance of the named General Contract of 29 July 2011.
The contract is identified by number, parties and subject, the retrofitting of fifty-one defence aircraft, so income from any other contract is outside the declaration.
Only Dassault Aviation is named as the beneficiary of the declaration, although the contract is described as one entered into with Thales Systemes Aeroportes as well.

Where you meet it

In the withholding position on payments under that defence contract, and in the foreign company's return where the receipt is excluded from total income.

On the same provision

Other instruments in this library that name the same provision of the 1961 Act. They are not necessarily still operative, and a later one may have replaced an earlier one without saying so.

Notification No. 116/2026 [F. No.195/13/2025-ITA-I] / SO 4706(E) : Notification in the case of Maharashtra Electricity Regulatory Commission — [भाग II—खण् ड 3(ii)] भारत का रािपत्र : असाधारण 3 25 August 2026
Notification No. 112/2026 [F. No. 300196/6/2026-ITA-I] / SO 4458(E) : Notification in the case of District Legal Service Authority, Panchkula — Ministry of Finance 11 August 2026
Notification No. 109/2026 [F. No. 300196/39/2025-ITA-I] / SO 4321(E) : Notification section 536 (1) of the Income Tax Act, 2025 (30 of 2025) in the case of Odisha Joint Entrance Examination Committee — [भाग II—खण् ड 3(ii)] भारत का रािपत्र : असाधारण 3 4 August 2026
Notification No. 107/2026 [F. No. 300196/65/2018-ITA-I] / SO 4319(E) : Notification section 536 (1) of the Income Tax Act, 2025 (30 of 2025) in the case of Noida Special Economic Zone Authority — [भाग II—खण् ड 3(ii)] भारत का रािपत्र : असाधारण 3 4 August 2026
Notification No. 106/2026 [F. No. 300196/65/2018-ITA-I] / SO 4318(E) : Notification section 536 (1) of the Income Tax Act, 2025 (30 of 2025) in the case of Noida Special Economic Zone Authority — [भाग II—खण् ड 3(ii)] भारत का रािपत्र : असाधारण 3 4 August 2026
Notification No. 104/2026 [F.No.300196/1/2026-ITA-I] / SO 4308(E) : Notification section 536 (1) of the Income Tax Act, 2025 (30 of 2025) in the case of District Legal Service Authority, Charkhi Dadri — Ministry of Finance 3 August 2026

← Notification No. 164/2015 [F.No.V. 27015/2/2015-SO (NAT.COM)]/SO 1632(E) · Notification No. 141/2015 [F.No.V. 27015/1/2015-SO (NAT.COM)]/SO 1571(E) →

What a notification is. A notification is made under a power the Act itself gives, and within that power it is law — unlike a circular, which only binds the department. Its reach is the reach of the enabling provision and no wider, and the date it carries decides from when it works.

Source: the Income Tax Department’s own published text — its page for this instrument.

What this is