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Income-tax Act, 2025 | Section 144

Section 144 - Special provisions in respect of newly established Units in Special Economic Zones

This preserves old section 10AA relief for eligible SEZ units. The old computation, remaining period and reinvestment-reserve conditions continue through the new section.

Reviewed by CA Nikhil Gupta · Updated 9 October 2026

Section 144: operativeEffective 1 April 2026Tax Year 2026-27 onwardLegally reviewed 8 October 2026

Current-law control

This page uses the consolidated Income-tax Act, 2025 as amended by the Finance Act, 2026. The Act and Income-tax Rules, 2026 operate from 1 April 2026. Earlier years and saved proceedings remain subject to the repeal-and-savings framework.

Primary statute: Income Tax Department consolidated Act   |   Rules: Notified Income-tax Rules, 2026

2-minute decode

This preserves old section 10AA relief for eligible SEZ units. The old computation, remaining period and reinvestment-reserve conditions continue through the new section.

Who should use this section

Eligible undertakings, enterprises or units claiming a profit-linked or transition deduction, generally subject to historical eligibility and audit conditions This applicability note is specific to section 144.

Old-law bridge

1961 Act section 10AA

The bridge is navigational only. A 1961 Act case or rule is carried forward only after checking wording, transition provisions and the current 2025 Act text.

Professional alert

Exception / professional alert Rule 67 requires Form 33 for the SEZ Reinvestment Allowance Reserve Account. Preserve export, foreign-exchange and unit-level evidence.

Connected Income-tax Rules, 2026 and Forms

RuleCurrent controlForm
Rule 66Audit report for profit-linked deductionsForm 32
Rule 67SEZ reinvestment particularsForm 33

Worked application

An SEZ unit in its residual 10AA period computes export profit and any reserve requirement under the preserved old law, then claims through section 144.

Evidence / compliance checklist

  • Maintain the original eligibility file for section 144, including commencement/approval history and the remaining deduction period.
  • Keep unit-wise books and a computation linking eligible profits to the qualifying undertaking or activity (section 144: Special provisions in respect of newly established Units in Special Economic Zones).
  • Where Rule 66 applies, obtain Form 32 and reconcile the accountant-certified figures to the return before the due date (section 144: Special provisions in respect of newly established Units in Special Economic Zones).
  • Preserve evidence that reconstruction, transfer, location, approval and other formation conditions continue to be satisfied (section 144: Special provisions in respect of newly established Units in Special Economic Zones).

Common mistake

Treating section 144 as a fresh 2026 tax holiday. For section 144, the preserved or transitional old-law eligibility must be checked specifically; the deduction clock does not restart merely because the 2025 Act is now in force.

Recommended approach

For section 144, fix the governing tax year, identify the operative sub-section for “Special provisions in respect of newly established Units in Special Economic Zones”, trace every amount to evidence, apply only verified Rule/Form links, and retain a computation that another reviewer can reproduce from the primary source.

Thresholds, periods and timing checkpoints

Judicial / interpretive bridge

No section-specific Supreme Court bridge is included for section 144 unless text-equivalence with the 2025 Act has been checked. Legacy cases should not be transplanted into section 144 merely because the subject is similar.

Related provisions

Current statutory text

144. In respect of any tax year, where— (a) in computing the total income of an assessee, being an entrepreneur as referred to in section 2(j) of the Special Economic Zones Act, 2005 (28 of 2005), who begins to manufacture or produce articles or things or provide any services, as referred to in section 10AA of the Income-tax Act, 1961 (43 of 1961); and (b) such assessee is eligible to claim a deduction from the profits and gains derived from the export, of such articles or things or from services for such tax year under the provisions of the said section, if the said Act had not been repealed, there shall be allowed, in computing the total income of the assessee, a deduction from the profits and gains derived from such business, subject to the conditions that— (i) the amount of deduction is calculated as per the provisions of section 10AA of the Income-tax Act, 1961 (43 of 1961); and (ii) the deduction under this Act shall be allowed only for such tax years, as would have been allowed under section 10AA of the Income-tax Act, 1961 (43 of 1961), as if the said Act had not been repealed.

Primary-source trail

FAQs

What does section 144 of the Income-tax Act, 2025 cover?

Section 144 covers special provisions in respect of newly established units in special economic zones. The operative result depends on the exact statutory conditions shown on this page and applies from 1 April 2026, subject to transition/savings provisions.

Who should check section 144?

Eligible undertakings, enterprises or units claiming a profit-linked or transition deduction, generally subject to historical eligibility and audit conditions This applicability note is specific to section 144.

Are there specific Rules or Forms for section 144?

Rule 66 - Audit report for profit-linked deductions / Form 32; Rule 67 - SEZ reinvestment particulars / Form 33

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