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<h1>Tax exemption for derivative income requires contracts with IFSC offshore banking units and exclusion of Indian permanent establishments.</h1> Exemption under clause (4E) of section 10 applies to income of a non-resident from transfer of non-deliverable forward contracts, offshore derivative instruments, or over-the-counter derivatives, and to distribution on offshore derivative instruments, provided the contract or instrument is entered into with an offshore banking unit of an International Financial Services Centre holding a valid registration or with a Foreign Portfolio Investor unit of an IFSC, and is not entered into through or on behalf of the non-resident's permanent establishment in India.