Deemed export for on site software development preserves tax incentives when linked by contract to the eligible Indian unit. Profits from software developed abroad at a client's site are deemed export and eligible for benefits under sections 10A, 10AA and 10B where there is a direct nexus and a contract between the client and the eligible Indian unit; deputation of technical manpower abroad for software work is similarly eligible when contractually engaged and conditions are met. Multiple SOWs under an MSA are permissible with SOW prevailing; Engineering and Design includes embedded R&D; slump-sale, SEZ relocation or setting up new units do not automatically defeat benefits, and separate books are not legally required though unit-level details may be sought.