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Microlesson · 5-min read

Amortisation of Preliminary Expenses [Section 35D]

# Amortisation of Preliminary Expenses [Section 35D]

Section 35D lets a business spread (amortise) certain pre-commencement / expansion expenses over 5 years, instead of denying them as capital outlay.

## Applicability

  • Indian companies and resident non-corporate assessees (i.e., all residents).
  • Before commencement: expenses incurred before business begins are eligible.
  • Expansion-related: expenses for extension of business or commencement of production in a new unit.

## Amount eligible

  • Total expenditure claimed shall not exceed:
  • Companies: higher of 5% of cost of project or 5% of capital employed.
  • Other assessees: 5% of cost of project.
  • Amortised over 5 years1/5th deductible each year, starting from the year of commencement/expansion.
  • The expenditure cannot be deducted again under any other section for the same or any other year.
  • Deduction allowed only if accounts are audited before the due date u/s 139(1).

## Eligible expenses

For all assessees:

  • Feasibility / project report preparation.
  • Market or other surveys essential for the business.
  • Engineering services related to business setup.
  • Legal charges for agreements relating to setting up the business.

Additionally for companies:

  • Legal charges for drafting the MOA and AOA.
  • Printing of MOA and AOA.
  • Incorporation fees under the Companies Act.
  • Costs of issuing shares/debentures — underwriting commission, prospectus expenses (flotation costs).

## Procedural requirement

  • The assessee must furnish a statement of expenditure within 1 month before the due date for filing the return u/s 139(1).

## Key definitions

  • Cost of the Project: actual cost of fixed assets as shown in the books on the last day of the previous year in which the business commences or extension happens.
  • Capital Employed: total of issued share capital + debentures + long-term borrowings as on the last day of the previous year of commencement/extension.

Worked example

### Example 1

Company ceiling (higher of two): A company incurs preliminary expenses of ₹12 lakh. Cost of project = ₹1.5 crore; capital employed = ₹2 crore. Ceiling = higher of 5% × ₹1.5 cr (₹7.5 lakh) and 5% × ₹2 cr (₹10 lakh) = ₹10 lakh. Only ₹10 lakh qualifies, amortised at ₹2 lakh/year for 5 years.

### Example 2

Non-corporate ceiling: A resident proprietor incurs ₹6 lakh preliminary expenses; cost of project = ₹80 lakh. Ceiling = 5% × ₹80 lakh = ₹4 lakh (capital-employed test is unavailable to non-companies). Annual deduction = ₹4 lakh ÷ 5 = ₹80,000 per year.

⚠️ Common exam mistakes

  • Using the 'higher of cost of project or capital employed' test for non-corporate assessees — they get only 5% of cost of project.
  • Amortising over the wrong period — it is always 1/5th over 5 years from the year of commencement/extension.
  • Forgetting that flotation costs (share/debenture issue, MOA/AOA) are eligible only for companies, not for non-corporate assessees.
  • Allowing 35D without the accounts being audited and the statement of expenditure being furnished within the prescribed time.
Reference: Section 35D
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