Exemption for non-deliverable forward contracts requires OBU registration and no involvement of the taxpayer's permanent establishment. Exemption under clause (4E) of section 10 applies only to income of a non-resident from transfer of non-deliverable forward contracts entered into with an offshore banking unit of an International Financial Services Centre holding a valid registration certificate from the International Financial Services Centres Authority, provided the contract is not entered into through or on behalf of the non-resident's permanent establishment in India, and the offshore banking unit must ensure compliance.