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Microlesson · 5-min read

Section 35D - Preliminary Expenses

# Section 35D: Preliminary Expenses

Expenses incurred before the commencement of business (or in connection with extension of an undertaking / setting up a new unit) are often capital-flavoured but have no tangible asset to attach to. Section 35D allows them to be amortised.

## Who Can Claim?

Resident assessees only (Indian companies, resident firms, individuals etc.).

## Eligible Preliminary Expenses

1. Preparation of feasibility study or project report

2. Conducting market survey or any other survey necessary for the business

3. Engineering services relating to the business

4. Legal charges for drafting agreements, etc.

5. Drafting & printing of MOA / AOA

6. Expenses on public issue of shares & debentures (underwriting commission, brokerage, etc.)

## Quantum of Deduction

### Indian Company

LimbDetail
(i) Actual qualifying expensesxxx
(ii) 5% of higher of: (a) Cost of project, (b) Capital employedxxx

Deduction = LOWER of (i) and (ii)

### Other Resident Assessee (non-corporate)

LimbDetail
(i) Actual qualifying expensesxxx
(ii) 5% of Cost of projectxxx

Deduction = LOWER of (i) and (ii)

Note: Non-company assessees don't get to use 'Capital Employed'.

## Amortisation Period

Deduction is spread over 5 equal annual installments, starting from the year of commencement (or year of completion of the extension/new unit).

## Key Definitions

  • Cost of Project = Amount invested in fixed assets for the new project.
  • Capital Employed = Share capital + Debentures + Long-term borrowings for the new project.
  • Reserves & Surplus are NOT included.

## Audit Requirement for Non-Companies

For an assessee other than a company or co-operative society, deduction under Sec 35D is only allowed if the accounts have been audited under Sec 44AB for that year.

Worked example

### Example 1

Example — Indian Company: Preliminary expenses Rs. 12,00,000. Cost of project Rs. 1,50,00,000. Capital employed Rs. 2,00,00,000.

  • Limb (i): Actual = Rs. 12,00,000
  • Limb (ii): 5% × higher of (1,50,00,000 ; 2,00,00,000) = 5% × 2,00,00,000 = Rs. 10,00,000

Qualifying = Lower = Rs. 10,00,000. Allowed in 5 installments = Rs. 2,00,000 p.a. for 5 years.

### Example 2

Example — Resident Firm: Preliminary expenses Rs. 8,00,000. Cost of project Rs. 1,00,00,000.

  • Limb (i): Actual = Rs. 8,00,000
  • Limb (ii): 5% × 1,00,00,000 = Rs. 5,00,000

Qualifying = Rs. 5,00,000. Allowed = Rs. 1,00,000 p.a. for 5 years (only if tax audit u/s 44AB is done).

⚠️ Common exam mistakes

  • Claiming the entire preliminary expense in year 1 instead of amortising over 5 years.
  • Including Reserves & Surplus in 'Capital Employed' — only share capital, debentures, and long-term borrowings count.
  • For non-corporate assessees, using the higher-of-cost-or-capital-employed limb (only Indian companies get that).
  • Allowing a non-resident to claim Sec 35D — restricted to residents.
  • Forgetting the Sec 44AB audit requirement for non-corporate, non-coop-society assessees.
  • Confusing 'cost of project' (fixed assets) with total project outlay (which may include working capital).
  • Claiming expenses other than the listed categories (e.g., general pre-incorporation salaries) under Sec 35D.
Bare-Act text Section 35D · Income-tax Act, 1961 · click to expand
Section 35D(1): Where an assessee, being an Indian company or a person (other than a company) who is resident in India, incurs, after the 31st day of March, 1970, any expenditure specified in sub-section (2) — (i) before the commencement of his business, or (ii) after the commencement of his business, in connection with the extension of his undertaking or in connection with his setting up a new unit — the assessee shall... be allowed a deduction of an amount equal to one-fifth of such expenditure for each of the five successive previous years beginning with the previous year in which the business commences.
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