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Microlesson · 5-min read

Section 35AD - Investment-Linked Deduction for Specified Business

# Section 35AD: Specified Business Deduction

Section 35AD allows a 100% deduction on capital expenditure incurred for setting up certain 'specified businesses' that the Government wishes to incentivise. Land, goodwill, and financial instruments are excluded.

## Specified Businesses (Mnemonic: A-H-I-W-I-H)

### Group 1 — Agriculture-linked

  • Setting up and operating a cold chain facility
  • Setting up and operating a warehousing facility for agricultural produce and sugar (edible oil NOT covered)
  • Production of fertiliser in India

### Group 2 — House / Hotel / Hospital

  • Developing & building a housing project under a Slum Redevelopment Scheme or Affordable Housing Scheme
  • Building & operating a hotel of 2-star or above category
  • Building & operating a hospital with minimum 100 beds

### Group 3 — Infra & specialised

  • Iron — Laying and operating a slurry pipeline for iron ore transportation
  • Wafer — Setting up & operating a semi-conductor wafer fabrication unit
  • Infrastructure — Developing, maintaining & operating a new infrastructure facility
  • HoneyBee-keeping and production of honey & wax

## Conditions to Qualify

1. New business — Must not be formed by splitting up or reconstructing an existing business.

2. New Plant & Machinery — Old P&M is restricted. Exceptions:

  • Up to 20% of total P&M may be old.
  • Imported second-hand P&M is allowed if depreciation has not been previously claimed in India.

3. No depreciation is allowed on assets on which Sec 35AD deduction has been taken (no double benefit).

4. No simultaneous claim under Sec 10AA or under Sec 80IA to 80RRB.

5. Pre-commencement capital expenditure that is capitalised in books in the year of commencement is allowed in full as deduction u/s 35AD in the year of commencement.

6. Mode of payment: Sec 40A(3) applies — any capital expenditure exceeding Rs. 10,000 to a single person in a single day must be by A/c payee cheque/DD/ECS/electronic mode.

## Loss Treatment

  • Unabsorbed loss of specified business can be carried forward indefinitely.
  • Loss of specified business can be set off only against income of another specified business — irrespective of whether that other specified business has itself claimed Sec 35AD or not.

## What is 'Infrastructure Facility'?

Includes: road (including toll road), bridge, rail system, highway project, water supply project, water treatment project, airport, inland waterways, etc.

## Misuse Provisions: Asset Sold / Used Outside Specified Business

The asset must be exclusively used for the specified business for 8 years from the date of acquisition.

### (A) If asset is used for non-specified business before expiry of 8 years:

```

Amount of deduction claimed earlier xxx

(-) Depreciation that would have been allowable (xxx)

if Sec 35AD had not been claimed

Net amount → added back to PGBP income xxx

```

Also, this net amount becomes the actual cost for the non-specified business (i.e., depreciation going forward starts on this base).

### (B) If asset is sold before expiry of 8 years:

The whole sale consideration is taxable as PGBP income — even if it exceeds the deduction originally claimed.

### (C) If used for non-specified business after expiry of 8 years:

No PGBP income arises. Actual cost = NIL for future depreciation.

### (D) If sold after expiry of 8 years:

Sale proceeds taxable as PGBP income.

Worked example

### Example 1

Example 1 — Basic deduction: A new 100-bed hospital is set up. Capital expenditure: land Rs. 50,00,000, building Rs. 2,00,00,000, medical equipment Rs. 1,00,00,000.

Deduction u/s 35AD = 2,00,00,000 + 1,00,00,000 = Rs. 3,00,00,000. Land (Rs. 50,00,000) is excluded.

### Example 2

Example 2 — Pre-commencement spend: Before commencing operations in PY 2026-27, the assessee incurred Rs. 30,00,000 on building (capitalised in books).

In PY 2026-27 (year of commencement), additional capex of Rs. 70,00,000 incurred. Total deduction u/s 35AD in PY 2026-27 = 30,00,000 + 70,00,000 = Rs. 1,00,00,000.

### Example 3

Example 3 — Asset misused after 5 years: Equipment cost Rs. 50,00,000 in PY 2022-23 (full deduction claimed). In PY 2027-28, asset shifted to a non-specified business. Depreciation @ 15% on WDV basis would have been Rs. 24,12,344 (notional).

Addition to PGBP = 50,00,000 − 24,12,344 = Rs. 25,87,656. Going forward, actual cost for non-specified business = Rs. 25,87,656.

### Example 4

Example 4 — Loss set off: Specified hospital business has loss of Rs. 5 lakh in PY. Specified hotel business (which did NOT claim Sec 35AD) has income of Rs. 8 lakh. The hospital loss CAN be set off against hotel income, even though hotel didn't claim Sec 35AD. Net PGBP from specified businesses = Rs. 3 lakh.

⚠️ Common exam mistakes

  • Claiming Sec 35AD on land or goodwill — never allowed.
  • Claiming depreciation on the same asset on which Sec 35AD deduction was taken (double benefit prohibited).
  • Treating edible oil warehousing as eligible — only agricultural produce & sugar are covered.
  • Allowing a 1-star hotel — must be 2-star or above.
  • Allowing a hospital with less than 100 beds — must be 100+ beds.
  • Setting off specified business loss against any business income (it must be against specified business income only).
  • Making capital payment in cash above Rs. 10,000 — falls foul of Sec 40A(3) discipline.
  • On sale before 8 years, only adding back the deduction (you must add entire sale consideration to PGBP).
  • On asset transferred to non-specified business before 8 years, forgetting to reduce notional depreciation while reversing the deduction.
  • Claiming Sec 80-IA to 80RRB or Sec 10AA along with Sec 35AD.
Bare-Act text Section 35AD · Income-tax Act, 1961 · click to expand
Section 35AD(1): An assessee shall, if he opts, be allowed a deduction in respect of the whole of any expenditure of capital nature incurred, wholly and exclusively, for the purposes of any specified business carried on by him during the previous year in which such expenditure is incurred by him. Provided that the expenditure incurred, wholly and exclusively, for the purposes of any specified business shall be allowed as deduction during the previous year in which he commences operations of his specified business, if the expenditure is incurred prior to the commencement of its operations and the amount is capitalised in the books of account of the assessee on the date of commencement of its operations.
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