1.    Introduction The Equalization Levy is a direct tax introduced by India to tax income accruing to non-resident companies from digital transactions with Indian customers or users, where the non-resident does not have a permanent establishment (PE) in India. It is contained in Chapter VIII of the Finance Act, 2016, and related rules, rather than the Income Tax Act, 1961, itself, but interacts with it via Section 10(50). 2.     Objective Tax digital transactions where the i