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Microlesson · 5-min read

Remuneration and Interest to Partners – Section 40(b) limits and taxability in partners' hands

## Remuneration to Working Partners — Section 40(b)

A partnership firm can claim remuneration paid to its working partners as a deduction, but only up to a statutory ceiling computed on Book Profits.

### Computing Maximum Remuneration Allowed

ParticularsAmount
A. Actual remuneration paid to working partnersXXXX
B. Maximum remuneration allowed:
→ On first ₹6,00,000 of Book Profits: higher of ₹3,00,000 or 90% of Book ProfitsXXX
→ On balance Book Profits: 60%XXX
C. Deduction = Lower of A or BXXXX

Thumb-rule: A firm can always pay up to ₹3,00,000 and claim the deduction irrespective of whether there is book profit or loss. The slab limits only need to be tested once the remuneration exceeds ₹3,00,000.

### Taxability in the Partner's Hands — Section 28(v)

Interest and remuneration received by a partner is taxable under PGBP in the partner's hands only to the extent it was allowed as a deduction to the firm.

  • If a firm pays ₹2,00,000 interest but only ₹1,00,000 is allowable under Section 40(b), then only ₹1,00,000 is taxable in the partner's hands.

### Conditions and Clarifications

  • Authorised by deed: Interest and remuneration are deductible only if explicitly authorised by the partnership deed.
  • Prospective only: Deduction is allowed only for payments relating to the period on or after the date of the deed — no deduction for payments before the deed date.
  • Non-working partners: No deduction at all for remuneration to a non-working partner.
  • TDS under Section 194T (w.e.f. 1.4.2025): TDS @ 10% applies on remuneration and interest paid by a firm to its partners if the sum exceeds ₹20,000.
  • Share of profit exempt: The partner's share of the firm's profit is exempt under Section 10(2A).
  • What is 'remuneration': Any salary, bonus, or commission (by whatever name called). Interest is NOT remuneration — do not club it.
  • Working partner: An individual actively engaged in conducting the business/profession of the firm.

Worked example

### Example 1

Example — Max remuneration computation. Book Profit = ₹10,00,000; actual remuneration paid = ₹8,00,000.

  • On first ₹6,00,000: higher of ₹3,00,000 or 90% of ₹6,00,000 (= ₹5,40,000) → ₹5,40,000
  • On balance ₹4,00,000: 60% → ₹2,40,000
  • Maximum allowed (B) = ₹5,40,000 + ₹2,40,000 = ₹7,80,000
  • Deduction = lower of actual (₹8,00,000) and B (₹7,80,000) = ₹7,80,000. Excess ₹20,000 is disallowed (and not taxable in the partner's hands per Section 28(v)).

### Example 2

Example — Loss situation. Firm has a book loss. Actual remuneration paid = ₹2,50,000. Since this does not exceed ₹3,00,000, the entire ₹2,50,000 is allowed as a deduction irrespective of the loss.

### Example 3

Example — Section 28(v) linkage. Firm pays interest of ₹2,00,000 to a partner but Section 40(b) limits the deduction to ₹1,00,000. The firm gets ₹1,00,000 deduction; correspondingly the partner is taxed on only ₹1,00,000 under PGBP.

⚠️ Common exam mistakes

  • Including interest within 'remuneration' when applying the Section 40(b) slabs — interest is computed separately (max 12% p.a.).
  • Forgetting the thumb-rule that ₹3,00,000 is allowed even in a loss year.
  • Taxing the full amount received by the partner under Section 28(v) instead of only the portion allowed to the firm.
  • Allowing deduction for remuneration to non-working partners or for the period before the deed date.
  • Ignoring the new Section 194T TDS @ 10% on partner payments exceeding ₹20,000 (w.e.f. 1.4.2025).
Reference: Sections 40(b), 28(v), 10(2A), 194T — Income-tax Act, 1961
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