Wipro - SEZ deduction
Facts
SEZ deduction under Section 10AA claim.
Issue
Scope of "profits derived from" SEZ unit - captive vs. external clients.
Held
Section 10AA deduction extends to profits from captive activities provided the unit is genuinely operating in the SEZ.
Ratio
"Derived from" SEZ unit is a substantive economic test, not a form test.
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