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Microlesson · 5-min read

Other Deductions under Section 36

# Other Deductions [Section 36]

Section 36 specifies various specific deductions allowable in computing PGBP income.

## (1) Stock Insurance [Sec. 36(1)(i)]

Insurance premium paid on stock-in-trade is allowed as deduction.

## (2) Health/Medical Insurance of Employees [Sec. 36(1)(ib)]

Premium for health/medical insurance of employees is allowed as deduction, provided it is paid by any mode OTHER than cash.

## (3) Bonus or Commission to Employees [Sec. 36(1)(ii)]

Bonus or commission paid to employees is allowed as deduction, subject to Section 43B (i.e., must be actually paid before due date of filing return under Section 139(1)).

Anti-abuse: such bonus/commission should NOT be in lieu of dividend that would have otherwise been paid.

## (4) Interest on Loan for Business Purpose [Sec. 36(1)(iii)]

```

For Depreciable Assets For Other Cases

| |

┌──────┴──────┐ |

| | |

Interest Interest Allowed u/s 36

UPTO AFTER [Subject to Section 43B]

put-to-use put-to-use

| |

Added to Allowed u/s 36

Cost of [Subject to Section 43B]

Asset

```

## (5) Discount on Zero Coupon Bond [Sec. 36(1)(iiia)]

Discount = (Maturity value − Issue price). It is amortised over the life of the zero coupon bond on a pro-rata basis and allowed as deduction.

## (6) Employer's Contribution for Benefit of Employees [Sec. 36(1)(iv) & related]

Eligible (Deduction Allowed u/s 36, subject to Section 43B)NOT Eligible (No Deduction)
Statutory Provident FundUnrecognised Provident Fund
Recognised Provident FundUnapproved Superannuation Fund
Approved Superannuation FundUnapproved Gratuity Fund
Approved Gratuity FundAny other fund (e.g., Employee Welfare Fund)
Any other fund as per law (e.g., ESI)

Section 43B Reminder: Even if liability is provided in books, deduction is allowed ONLY when the payment is actually made on or before the due date of furnishing the return of income under Section 139(1).

Worked example

### Example 1

Example — Interest on loan for depreciable asset:

ABC Ltd. took a loan of ₹ 50,00,000 for purchase of plant. The plant was purchased on 1.4.2025 and put to use on 1.10.2025. Interest of ₹ 6,00,000 was paid for the year, of which:

  • ₹ 3,00,000 relates to the period 1.4.2025 to 30.9.2025 (pre put-to-use)
  • ₹ 3,00,000 relates to the period 1.10.2025 to 31.3.2026 (post put-to-use)

Treatment:

  • ₹ 3,00,000 (pre put-to-use) → Added to cost of asset (depreciation allowed on this portion)
  • ₹ 3,00,000 (post put-to-use) → Allowed as deduction under Sec. 36(1)(iii) in P.Y. 2025-26 (subject to Section 43B)

### Example 2

Example — Employer contribution to funds:

XYZ Ltd. made the following contributions during P.Y. 2025-26:

  • Recognised Provident Fund: ₹ 5,00,000 (paid before due date of return)
  • Unrecognised Provident Fund: ₹ 1,00,000
  • Approved Gratuity Fund: ₹ 2,00,000 (paid before due date of return)
  • Employee Welfare Fund (no specific law): ₹ 50,000

Allowable Deduction:

  • RPF: ₹ 5,00,000 ✓
  • URPF: NIL ✗
  • Approved Gratuity Fund: ₹ 2,00,000 ✓
  • Employee Welfare Fund: NIL ✗
  • Total Deduction = ₹ 7,00,000

⚠️ Common exam mistakes

  • Allowing employer contribution to unrecognised PF / unapproved funds — NO deduction is permitted.
  • Paying health insurance premium of employees in cash — only NON-cash modes qualify.
  • Adding post-put-to-use interest to cost of asset — only PRE-put-to-use interest is capitalised; the rest goes to P&L.
  • Forgetting Section 43B — bonus, commission, employer PF/gratuity contributions, and post-put-to-use interest are all subject to actual-payment requirement on or before due date u/s 139(1).
  • Treating discount on zero coupon bond as a single-year deduction — it must be amortised over the bond's life.
  • Paying bonus/commission to a director-shareholder in lieu of dividend — the AO can disallow such amounts.
Bare-Act text Section 36(1) · Income Tax Act, 1961 · click to expand
Section 36(1) — The deductions provided for in the following clauses shall be allowed in respect of the matters dealt with therein, in computing the income referred to in section 28: (i) the amount of any premium paid in respect of insurance against risk of damage or destruction of stocks or stores used for the purposes of the business or profession; (ib) the amount of any premium paid by any mode of payment other than cash by the assessee as an employer to effect or to keep in force an insurance on the health of his employees... (ii) any sum paid to an employee as bonus or commission for services rendered, where such sum would not have been payable to him as profits or dividend if it had not been paid as bonus or commission; (iii) the amount of the interest paid in respect of capital borrowed for the purposes of the business or profession; (iv) any sum paid by the assessee as an employer by way of contribution towards a recognised provident fund or an approved superannuation fund...
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