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Case lawCBDT Circulars & Instructions › Statutory position — s.10AA: the SEZ deduction, its fifteen-year run, and the commencement sunset
CBDT Circulars & InstructionsCuts both wayss.10AAs.10AA(1)s.10AA(2)s.10AA(3)s.10A(1B)s.139(1)

Statutory position — s.10AA: the SEZ deduction, its fifteen-year run, and the commencement sunset

A client wants to set up a new SEZ unit. Can it still claim s.10AA, and what exactly does an existing unit get in years eleven to fifteen?

A client wants to set up a new SEZ unit. Can it still claim s.10AA, and what exactly does an existing unit get in years eleven to fifteen?

No new unit can get into s.10AA. The section applies only where the Unit begins to manufacture or produce articles or things or provide services "during the previous year relevant to any assessment year commencing on or after the 1st day of April, 2006, but before the first day of April, 2021", so the gate is shut on anyone commencing now. The last previous year in which a Unit could commence and qualify is FY 2019-20, that is, commencement by 31 March 2020. For a Unit that got in before the cut-off the deduction runs for fifteen assessment years: hundred per cent of the profits derived from export for the first five, fifty per cent for the next five, and for the last five so much of the profit, not exceeding fifty per cent, as is debited to the profit and loss account and credited to a Special Economic Zone Re-investment Reserve Account.

Decided by the CBDT Circulars & Instructions (Not applicable — statutory text) on 2017-04-01, reported as Section 10AA as printed on the Income Tax Department's section page, "Year: 2026"; https://incometaxindia.gov.in/w/section-10aa. It bears on section 10AA, section 10AA(1), section 10AA(2), section 10AA(3), section 10A(1B), section 139(1) of the Income Tax Act 1961, in Capital Gains Exemptions and Deductions & Disallowances matters.

Still good law. This is the text as the Income Tax Department printed it on 8 September 2026 under the stamp "Year: 2026", transcribed on two separate fetches with identical wording on both. The current page carries no amendment footnote list, but the commencement of the cut-off words is established from the footnotes on the year-stamped archived pages for 2016 and 2017 (Act No. 28 of 2016, w.e.f. 1-4-2017). No amendment later than the Finance Act 2023 was checked for and none is asserted. The 1961 Act continues to govern every assessment year up to and including AY 2026-27 by virtue of s.536 of the Income-tax Act, 2025. No position under the 2025 Act is stated.

Why it matters

Practitioners still receive s.10AA queries from promoters who have been told the SEZ scheme is open. It is not: the deduction is closed to new entrants and every remaining claim is a run-off claim on a unit that commenced years ago. The years eleven to fifteen are where the disputes now sit, because that tranche is not automatic — it is capped at the amount actually debited to the profit and loss account and credited to the reserve, the reserve must be spent on machinery or plant first put to use within three years of the year the reserve was created, and until it is spent it may be used only for the business of the undertaking and not for dividends, for remittance outside India as profits, or for creating any asset outside India. s.10AA(3) then claws the money back: an amount used for any other purpose is deemed to be profits of the year of misuse, and an amount left unspent is deemed to be profits of the year immediately following the three-year period. The eligibility conditions live in s.10AA(4) and the realisation condition in s.10AA(4A); those are separate entries.

Binding on the department, not on the assessee or the courts. An assessee may rely on a circular that is beneficial to them.

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Related

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