Objectives & Agenda : To analyse and interpret the provisions of the Income-tax Act relating to computation of 'Profits and gains of business or profession' (PGBP). In this Webinar, we shall look at the charging section for PGBP and provisions relating to computation of PGBP, admissible deductions and allowances including Depreciation.

1. Understanding Income Tax - Profits &
Gains of Business or Profession
[Sec 28 – Sec 33ABA]
CA. Divakar Vijayasarathy

2. Credits and Acknowledgments
Bharathi Priya R D
CA. Jugal Gala

3. Legends used in the Presentation
AOP Association of Persons
BOI Body of Individuals
CG Central Government
CTT Commodities Transaction Tax
PY Previous Year

4. Presentation Schema
Charging Section
Meaning of Business &
Profession, Charging
Section & Speculative
Transaction
Computation of
Income under the
Head “PGBP”
Deductions from
Business /
Professional income
Depreciation
Additional
Depreciation
Rates of
Depreciation
Special Provisions
for Change in
Exchange Rate
Unabsorbed
depreciation
Investment
Allowance
Specified Deduction for
Business of Growing and
manufacturing Tea,
Coffee and Rubber
Site Restoration
Fund

5. Meaning of Business and Profession
• Business includes trade, commerce, manufacture, adventure or concern in the nature of
trade, commerce or manufacture
Business
Sec 2(13)
• Profession includes vocation
• However, in normal parlance, profession refers to professed attainment in special
knowledge as distinguished from mere skill
• Thus, income of painter, sculptor, author, auditor, lawyer, doctor, architect, etc. will be
treated as professional income
Profession
Sec 2(36)

6. Charging Section – Sec 28
Following incomes shall be chargeable under the head "Profits and gains of business or profession"
Profits and gains of any business or profession carried on by the assessee at any time during the PY
Any compensation received or receivable, in connection with termination or modification of terms and conditions, by any
person
• Managing the affairs of an Indian Company
• Managing the affairs in India of any other company
• Holding an agency in India for the business of any other person
• Compensation received for vesting with the Government, or in any corporation owned or controlled by it, of any
property or business
• Compensation received in respect of termination or the modification of the terms and conditions, of any contract
relating to his business
• Note: The above compensation does not include instances where the sum is received in the capacity of an employee.
Where an employee receives such compensation from his employer, the same would be treated as “Income from
Salaries”
Income derived by trade, professional or similar association from specific services performed for its members
Profit on sale of Import Licenses

7. Contd.
Cash assistance against exports received under any Government scheme
Duty drawback under Customs and Excise Rules
Profit on sale of Duty Entitlement Pass Book Scheme
Profit on sale of Duty Free Replenishment Certificate
Value of any benefit or perquisite, whether convertible into money or not, arising from any business or profession
Interest, salary, bonus, commission or remuneration due to or received by a partner from his firm, to the extent allowed
under Sec 40(b)
Any sum received or receivable in cash or in kind for the purpose of
• Not carrying out any activity in relation to any business (not if chargeable under “Capital gains”), or
• Not sharing any know how, patent, copyright, trade mark, license, franchise or any other right of similar nature or
information or technique likely to assist in the manufacture or processing of goods or provision for services

8. Contd.
Sum received under a Keyman Insurance Policy including bonus
Fair market value of inventory as on the date on which it is converted into, or treated as, a capital asset determined in the
prescribed manner
Any sum, whether received or receivable, in cash or kind, on account of any capital asset (other than land or goodwill or
financial instrument) being demolished, destroyed, discarded or transferred, if the whole of the expenditure on such capital
asset has been allowed as a deduction under Sec 35AD
• Note: 100% deduction is available on capital assets held by assessee specified u/s 35AD. If such asset is sold, entire sale
proceeds shall be regarded as business income
Where the assessee is into speculative and other businesses, income from speculative business shall be treated as distinct
and separate from any other business

9. Meaning of Speculative Transaction – Sec 43(5)
A contract entered to guard against loss due to price fluctuations (hedging contracts) in the following cases
Raw materials in the normal course of business
Stocks and shares entered by dealer or investor
Member of a forward market or stock exchange in the course of jobbing or arbitrage.
Transfer of Derivatives where commodities transaction tax is charged (no CTT for agricultural commodity derivatives),
•It is carried out electronically on screen based systems through registered brokers/ sub brokers/ intermediary
•Transaction is supported by a Time Stamped Contract Note issued by such broker/ sub broker/ intermediary indicating
the Unique identification number and PAN
Transaction involving a contract for purchase and sale of commodities including stocks and shares, which is periodically or
ultimately, settled other than by actual delivery or transfer of commodities or scrips
Exceptions
Distinction between normal business and speculative business is imperative because
• Speculative losses can be set off only against speculative income, and
• Regular business loss can be set off against both speculative income & regular business income

10. Computation of income under the head Profits and
Gains of Business or Profession – Sec 29
Section Description
30-37 Deductions from Business / Profession Income
38 Treatment of assets not exclusively used for Business or Profession
40/40A/43B Amounts not deductible
41 Deemed profits
42 Special provisions pertaining to prospecting mineral oils
43 Definitions of certain terms relevant to income from profits and gains of business or profession
43A Special provisions consequential to changes in rate of exchange of currency
43AA Taxation of foreign exchange fluctuation
43C Special provision for computation of cost of acquisition of certain assets
43CA Special provision for full value of consideration for transfer of assets other than capital assets in certain
cases
43CB Computation of income from construction and service contracts
43D Special provisions pertaining to Public financial institutions
Income under Sec 28 shall be computed in accordance with Sec 30 to 43D which are briefed as under

11. Deductions from Business / Profession Income
(Sec 30-37)
Expenditure on buildings – Sec 30
Actual rent paid in the case of rented premises
Current repairs (Excludes capital expenditure)
Payment of taxes like land revenue, local rates or municipal tax
Insurance premium paid against risk of damage or destruction of the premises
Municipal taxes paid by the assessee are allowed subject to Sec 43B (deductions to be only on actual
payment irrespective of year)
Following expenses are allowed as deduction

12. Expenditure of Machinery, Plant and Furniture – Sec 31
Current repairs (Excludes capital expenditure)
Insurance premium paid against risk of damage or destruction
Following expenses are allowed as deduction
Plant includes ships, vehicles, books, scientific apparatus and surgical equipment used for
the purposes of the business or profession but does not include tea bushes or livestock or
buildings or furniture and fittings
Meaning of Plant – Sec 43(3)

13. Depreciation – Sec 32
Depreciation refers to the gradual decline in the value of an asset owing to passage of time, wear and tear or obsolescence
Block of assets – Sec 2(11)
Block of assets means a group of assets falling within a class of assets carrying
similar rates of depreciation
Class of assets
Intangible Assets
Tangible Assets
Buildings
Furniture and
Fittings
Plant and
Machinery
Know how CopyrightsPatents TrademarksLicenses Franchise
Any other business
or commercial rights
of similar nature
Group of assets refer to a collection of assets belonging to the same class (building, plant etc) and eligible for
the same rate of depreciation

14. Written Down Value – Sec 43(6)
Situation Written down value
Assets acquired before the PY Actual Cost
Less: Depreciation allowed till beginning of the PY
In the case of Composite businesses (agricultural and non-agricultural
business)
Actual Cost
Less: Depreciation allowed till beginning of the PY (including
depreciation on the portion of agricultural income)
Assets acquired during the PY Actual Cost
Asset acquired in a scheme of Amalgamation Written down value of amalgamating company
Asset acquired in a scheme of Demerger Written down value of Demerged company
Asset acquired in a scheme of Succession Written down value of the Predecessor Company
Assets transferred by recognised stock exchange under a scheme of
corporatisation
WDV of the transferred assets immediately before transfer
Transfer from holding to 100% subsidiary and vice versa Written down value of the transferor company
Written down value where the assessee was not required to
compute his total income for any PY
- Actual cost shall be adjusted by the amount of revaluation if any on
the asset (-) Total depreciation allowed as per books for the PY
immediately preceding the relevant PY shall be deemed to the total
depreciation allowable under the Act
- The above depreciation shall be adjusted to the extent of revaluation
if any on the asset
Asset acquired in a scheme of conversion of a private limited
company or public unlisted company into an LLP
Written down value of the Predecessor Company

15. Actual Cost – Sec 43(1)
Actual Cost – Sec 43(1)
Actual cost to the assessee refers to cost of an asset reduced by the portion of cost
incurred/met directly or indirectly by any other person or authority
Actual cost to the assessee (excluding cash payments exceeding Rs. 10,000) XXX
Less: Portion of cost met directly or indirectly by any other person (XXX)
Actual cost for depreciation XXX
Explanation no.
to Sec 43(1)
Situation Actual Cost
1 Asset used for business after being used for
Scientific research
Actual cost Less: Deduction
allowed under Sec 35
Note: Deduction under Sec 35 varies from 100% to 150% of actual cost.
Hence in all cases, actual cost of the asset would be restricted to Nil. Actual
cost cannot be negative
1A Stock in trade is converted into capital asset Fair market value as on the
date of conversion
2 Asset acquired by way of gift or inheritance Written down value of the
previous owner

16. Contd.
Explanation no.
to Sec 43(1)
Situation Actual Cost
3 Any asset transferred at enhanced cost to
reduce tax Liability
Amount determined by the Assessing Officer with
the prior approval of Joint Commissioner
4 Where an asset owned and used by the
assessee for business, was transferred and
now reacquired by him
Written down value at the time of initial transfer
or reacquisition price, whichever is less
Note: The provision is silent on the period between the transfer and reacquisition date. Hence it
may be assumed that even if the assessee is reacquiring an asset after 5 or 10 years from the
date of original transfer, the above provisions would still apply
4A Sale and Lease back transactions: Where an
assessee, after having used an asset,
transfers the asset to a third party and
reacquires the same asset on lease from
such party
Actual cost to the purchaser
(Lessor) shall be Written down value of seller at
the time of transfer
5 Building purchased for personal use,
subsequently used for business purposes
Actual purchase cost
Less: Depreciation from the year of acquisition till
the year of putting the asset into use for business
purposes
Note: Rate for depreciation is the rate on the date of putting the asset for business use.
This provision is applicable only for buildings and not for any other personal asset held by the
assessee

17. Contd.
Explanation no.
to Sec 43(1)
Situation Actual Cost
6 Transfer from holding to 100% subsidiary
company referred to in Sec 47(iv) or vice versa
under Sec 47(v)
Cost to transferee company shall be written
down value of the transferor company
7 Assets transferred at the time of
amalgamation
Written down value in the hands of
amalgamating company
7A Assets transferred at the time of demerger Written down value in the hands of demerged
company
8 Interest on borrowed capital Interest till the date of putting the asset to use
shall be capitalized
Interest subsequent to the date of putting the
asset to use shall be charged as revenue
expenditure
For the purpose of taxation, interest shall be capitalized till the date the asset is actually put to
use and not on the date when the asset is ready for use
9 If CENVAT credit or ITC is not claimed Actual cost less credit not claimed
10 Where a portion of the actual cost is met by
some other person e.g. : Grants, subsidy etc.
Reduce actual cost by such amount of cost met
by the other person
11 Asset acquired outside India by a Non resident
and brought into India for business purposes
Actual Cost Less: Depreciation from date of
acquisition till date of bringing it into India

18. Contd.
Explanation no. to
Sec 43(1)
Situation Actual Cost
12 Assets acquired from a recognised stock exchange under a scheme of
corporatisation or demutualisation
WDV in the hands of recognised
stock exchange
13 Actual cost of any capital asset on which deduction has been allowed or is
allowable to the assessee under Sec 35AD for:
- the assessee
- to any other person who has received such asset by way of:
• gift, will or an irrevocable trust
• distribution on liquidation of the company exempted transfers u/s 47
namely:
• distribution on total or partial partition of HUF – Sec 47(i)
• transfers between holding and subsidiary companies – Sec 47(iv)/(v)
• transfer in a scheme of amalgamation – Sec 47(vi)
• transfer in a scheme of demerger – Sec 47(vib)
• succession of a partnership to a company – Sec 47(xiii)
• conversion of a private limited company or a public unlisted
company into an LLP – Sec 47(xiiib)
• succession of a sole proprietary concern to a company – Sec 47(xiv)
NIL.
In case deduction allowed is
deemed as income in the hands of
assessee, actual cost shall be the
actual cost to the assessee less
depreciation that would have been
allowable had the asset been used
for the purpose of business since
the date of its acquisition

19. Conditions for Claiming Depreciation
Asset is either wholly or partly owned by the assessee (assets registered in partner’s name, firm can claim if for business
purpose)
Asset is used (not passive use) by the assessee during the PY for his business or profession
The provisions of depreciation shall apply whether or not the assessee has claimed the deduction in respect of depreciation
while computing his total income. Hence claiming depreciation under Sec 32 is mandatory- Explanation 5 to Sec 32(1)(ii)
• Owner need not be registered owner
• Building does not include land
• Land is not a depreciable asset hence no depreciation can be claimed on land
• Roads laid within the factory premises, fencing, drainage etc within factory compound are included as part of Buildings
• Leasing business – depreciation allowed; temporary leased out – no depreciation shall be allowed
Capital expenditure on a leased building in relation to renovation, extension or improvement etc. shall be
eligible for depreciation: Explanation 1 to Sec 32(1)

20. Depreciation in the Event of Succession
In the case of succession under the following circumstances, depreciation for the year of
succession shall be computed as if such succession has not taken place
Conversion of a
partnership firm to a
company - Sec 47(xiii)
Conversion of a private
limited company or unlisted
public company to a
company - Sec 47(xiiib)
Conversion of a sole
proprietary concern to a
company - Sec 47(xiv)
Succession to business
otherwise than on death -
Sec 170(2)
Amalgamation
Demerger
The total depreciation computed shall be apportioned between the predecessor and
successor entities in the ratio of the number of days for which the asset was held by
the respective assesses

21. Computation of Depreciation
Opening written down value of the block XXX
Add: Additions to the block XXX
Less: Moneys payable where any asset is: Sold, discarded, demolished or
destroyed Including scrap value
(XXX)
Value of the block before depreciation XXX
Less: Depreciation at the rates prescribed (XXX)
Written down value XXX
Depreciation is always computed on the written down value at the end of the year except in the
case of electricity companies (explained later) which can exercise the option to claim
depreciation on Straight line method
If asset is used for >= 180 days in the PY 100% depreciation is allowed
If asset is used for < 180 days in the PY 50% depreciation is allowed
“Moneys payable” in respect of any building, machinery, plant or furniture includes any
insurance, salvage or compensation moneys payable in respect thereof and, where the
aforementioned assets are sold, the price for which it is sold - Explanation to Sec 41(4)
However, if the asset was
purchased say during F Y 2018-
19 but put to use on 01.10.2019,
then depreciation shall be fully
allowed for F Y 19-20; however,
no depreciation shall be allowed
for F Y 18-19

22. Additional Depreciation – Sec 32(iia)
Where an assessee engaged in the business of manufacture or production or in the business of generation, transmission or
distribution (not only distributor) of power (thermal, hydel or solar power)
Has acquired and installed any new plant and machinery (other than ships, aircraft and used plant and machinery)
A further sum of 20% of the actual cost of such machinery or plant shall be allowed as deduction
For Andhra Pradesh, Bihar, Telangana or West Bengal – additional depreciation shall be 35% (on or after 1st April 2015)
Provided that, no deduction shall be allowed in respect of:
• Plant and machinery which was used by any other person, either within or outside India
• Plant and machinery installed in any office premises or residential accommodation including guest house
• Any office appliance or road transport vehicle
• Any plant and machinery eligible for 100% depreciation/deduction
If asset is used for < 180 days in the PY 50% additional depreciation is allowed

23. Rates of Depreciation

24. Contd.

25. Contd.

26. Special Provisions Consequential to Changes in Rate
of Exchange of Currency – Sec 43A
If an assessee has acquired any asset in any PY from a country outside India for the purpose of his business or profession
Asset shall be initially capitalized at the rate of exchange prevailing on the date of acquisition
Where an assessee has acquired an asset on credit or deferred payment basis or by taking a forex loan
Any increase or decrease in the liability towards repayment of capital borrowed, owing to exchange fluctuations, shall be
added to or reduced from the written down value of the asset in the year of actual payment
Where the assessee has entered into a forward contract, the rate of exchange shall be rate as specified in the contract
If the asset on which forex loan was taken, is sold before the effect of fluctuation arises, then the effect shall be adjusted to
the remaining value of the Block
Where the block ceases to exist upon sale of the asset, then fluctuation effect will be capital receipt or expenditure and will
not have any tax implications
The provisions of this section shall apply in the following situations:
• Actual cost of an asset under Sec 43(1)
• Amount of capital expenditure incurred on scientific research under Sec 35(1)(iv)
• Capital expenditure on family planning under Sec 36(1)(ix)
• Cost of acquisition of a capital asset under Sec 48

27. Special provisions regarding undertaking engaged in the
generation or generation and distribution of power - Sec
32(1)(i)
Assessee is given an option to choose between straight line method or written down value
Where no option is chosen, straight line method shall be deemed to have been adopted
In Straight line method, depreciation shall be allowed as a percentage of the actual cost
Aggregate depreciation allowed shall not exceed actual cost
Block of assets concept is not applicable

28. Unabsorbed Depreciation – Sec 32(2)
Unabsorbed depreciation refers to excess depreciation over and above available profits
Unabsorbed depreciation arises in the event of inadequate profits or loss
The salient features of unabsorbed depreciation are as follows:
• Unabsorbed depreciation of a PY shall be carried forward to subsequent PY’s and shall be eligible for set off against
available surplus of such subsequent PY’s
• Unabsorbed depreciation shall be regarded as depreciation of the year of set off
Hence unabsorbed depreciation can be set off against available business profits or any other head of income in accordance
with the provisions of Chapter VI (Sec 70-80): Set off and carry forward of loss
In case of amalgamation or demerger, unabsorbed depreciation of erstwhile company shall be deemed to be the
depreciation of amalgamated or resulting company

29. Investment Allowance – Sec 32AD
• 15% of the actual cost of new plant and machinery
Eligible
Deduction
• Set up manufacturing unit in notified backward areas
• Unit Set up on after 01.04.2015
• Plant and Machinery acquired and installed between 01.04.2015 to 31.03.2020
Conditions
• West Bengal
• Andhra Pradesh
• Bihar
• Telangana
Notified
backward
areas
(Specified
states)
• any new plant or machinery (other than a ship or aircraft) but does not include:
• Used machinery
• Used for personal or non-manufacturing purposes
• Any vehicle or office appliance/installed in residential accommodation
• Asset on which full cost claimed as deduction earlier
New Plant and
Machinery
• Should not be sold or transferred otherwise, within 5 years from date of installation
• Consequence – Deduction allowed is deemed as income in the PY of such sale or transfer
• Shall not apply in case of transfer due to amalgamation or demerger
• However, Shall continue to apply to Resultant company
Minimum
Holding Period
and
Consequences

30. Deduction in Respect of Assessees Engaged in the Business
of Growing and Manufacturing Tea, Coffee and Rubber –
Sec 33AB
• All assessees engaged in the business of Growing and Manufacturing tea, coffee or rubber in India
Eligible
Assessee
• Assessee should make a deposit with:
• NABARD under a specific scheme approved by the respective Board (Tea, Coffee or rubber).
• Deposit account under a scheme framed by the respective Board and approved by CG
Deposit
Condition
• Within 6 months from the end of the PY, or
• Before furnishing return of income, whichever is earlier
Time Limit
for Deposit
• Deduction shall be the least of the following
• Amount deposited, or
• 40% of profits for the year under the head Profits and Gains of business or profession
• No Deduction shall be allowed under this section in the hands of partner of a firm, member of an AOP/BOI
if deduction is claimed under this section by the firm, AOP/BOI
Amount of
Deduction
Accounts of the assessee are required to be audited and auditors report in the
prescribed Form 3AC needs to be furnished

31. Contd.
• Where separate accounts are maintained by the assessee, then profits computed from the business of
growing and manufacturing tea, rubber and coffee shall be considered for deduction
• Where separate accounts are not maintained by the assessee, profits shall be computed using the
formula given below:
• Profits of all Business * Turnover from growing & manufacturing Tea/ Rubber /Coffee
Computation
of Profits
• Business purposes
• Purchase of assets except the following:
 Plant and Machinery installed in any office or residential accommodation including guest house Office
appliances except computers
 Any plant and machinery eligible for 100% depreciation or deduction
 Any new machinery or plant installed in an industrial undertaking engaged in the production of
articles mentioned in the Eleventh schedule.
• Note: If the amount withdrawn is not utilized for the above purposes then it shall be added to assessee’s
income under the head Profits and Gains of Business or Profession of the year of such violation.
Utilization of
Amount
deposited
Total turnover of assessee’s business

32. Contd.
Amount deposited cannot be withdrawn except for the purposes mentioned in the scheme and also in the
case of the below mentioned circumstances:
• Closure of business
• Dissolution of the firm
• Death of an assessee
• Partition of an HUF
• Liquidation of a company
Withdrawal of Deposit
1.Withdrawal for the reasons 1 & 2 are taxable. The amount withdrawn shall be added to assessee’s income
under the head Profits and Gains of Business or Profession
2. Withdrawal for the reasons 3 to 5 are not taxable

33. Contd.
Withdrawal of Deduction
Situation Amount of Deduction withdrawn
Where the amount withdrawn is not utilized during the PY or is
not utilized for the purposes of scheme
Unutilized amount shall be treated as income and
charged to taxation
Where the newly acquired asset is transferred or sold within a
period of 8 years from the end of the previous year in which
such asset was purchased
Such part of the cost of the asset as is relatable to the
deduction allowed
The period of 8 years shall not apply where
The asset is transferred to Government / Local authority/Corporation or Government Company
Transfer is on account of succession of a firm by a company provided:
• All assets and liabilities of the firm immediately before transfer become the assets and liabilities of the company
• All the shareholders of the company were partners of the firm

34. Contd.
Rule Nature of Business Agricultural Income Non Agricultural Income
7A Growing and Manufacturing
Rubber
65% 35%
7B Coffee Grown and Cured in
India
75% 25%
Coffee Grown, Cured, roasted
and ground in India
60% 40%
8 Growing and Manufacturing
Tea
60% 40%
As per Rules, before disintegrating business profits, income should be computed under the
head “Profits and Gains of Business or Profession” implying deduction under Sec 33AB shall
be given prior to disintegration
Deduction is subject to following rules, which contains provisions relating to splitting of
business income between agricultural and non agricultural income as follows
Rule 8 shall apply after profit or loss is determined from the specified business and
permissible deductions under the Act.

35. Site Restoration Fund – Sec 33ABA
• All assessees engaged in the business of prospecting / extraction / production of Petroleum / natural gas in
respect of which CG has entered into an agreement with the assessee
Eligible
Assessee
• Assessee should make a deposit with:
• SBI in a scheme approved by Ministry of Petroleum and Natural Gas, or
• Site Restoration Account in accordance with a scheme framed by the Ministry
Deposit
Condition
• Before the end of the PY
Time Limit
for Deposit
• Deduction shall be the least of the following
• Amount deposited, or
• 20% of profits for the year under the head Profits and Gains of business or profession
• No Deduction shall be allowed under this section in the hands of partner of a firm, member of an AOP/BOI
if deduction is claimed under this section by the firm, AOP/BOI
Amount of
Deduction
Accounts of the assessee are required to be audited and auditors report in the
prescribed Form 3AD needs to be furnished

36. Contd.
• Business purposes
• Purchase of assets except the following:
 Plant and Machinery installed in any office or residential accommodation including guest house
 Office appliances except computers
 Any plant and machinery eligible for 100% depreciation or deduction
 Any new machinery or plant installed in an industrial undertaking engaged in the production of
specified articles
• Note: If the amount withdrawn is not utilized for the above purposes then it shall be added to assessee’s
income under the head Profits and Gains of Business or Profession of the year of such violation
Utilization of
Amount
deposited
• Amount deposited cannot be withdrawn except for the purposes mentioned in the scheme
Withdrawal of
Deposit

37. Contd.
Withdrawal of Deduction
Situation Amount Taxable as Income
Amount withdrawn on closure of the Account Amount withdrawn (-) amount payable to CG by way of
profit or production share
Where the amount withdrawn is not utilized during the PY or is
not utilized for the purposes of scheme
Unutilized amount shall be treated as income
and charged to taxation
Where the newly acquired asset is transferred or sold within a
period of 8 years from the end of the previous year in which
such asset was purchased
Such part of the cost of the asset as is relatable
to the deduction allowed
The period of 8 years shall not apply where
The asset is transferred to Government / Local authority/Corporation or Government Company
Transfer is on account of succession of a firm by a company provided:
• All assets and liabilities of the firm immediately before transfer become the assets and liabilities of the company
• All the shareholders of the company were partners of the firm

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