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Microlesson · 5-min read

Capital Expenditure for Specified Businesses [Section 35AD]

# Deduction for Specified Businesses [Section 35AD]

Section 35AD allows a 100% deduction of capital expenditure for certain notified specified businesses, as an investment-linked incentive (replacing area-based profit-linked deductions).

## The 14 specified businesses

1. Cold chain facilities for specified products.

2. Warehousing facilities for agricultural produce.

3. Cross-country natural gas / crude oil / petroleum pipeline network incl. storage (companies only).

4. Building & operating hotels rated two-star or higher, anywhere in India.

5. Hospitals with at least 100 beds, anywhere in India.

6. Housing under notified slum redevelopment/rehabilitation schemes.

7. Housing under notified affordable housing schemes.

8. Producing fertilizers in India.

9. Inland container depot / container freight station (approved under Customs Act, 1962).

10. Bee-keeping and production of honey & beeswax.

11. Warehousing facilities for sugar.

12. Slurry pipeline for transporting iron ore.

13. Semiconductor wafer fabrication unit (subject to Board notification).

14. Developing, maintaining & operating a new infrastructure facility.

## Amount of deduction

  • 100% of capital expenditure incurred wholly and exclusively for the specified business.
  • Pre-commencement capital expenditure is deductible in the year of commencement, provided it is capitalised in the books on the commencement date.
  • No deduction for cost of land, goodwill, or financial instruments.
  • Payments exceeding ₹10,000 to a single person in a day must be through banking channels (except bearer cheque/bearer draft) to qualify.
  • For individuals, HUF, AOP, BOI, AJP — deduction available only under the optional (old) regime.
  • Companies opting for 115BAA / 115BAB are not eligible.
  • Once 35AD is claimed, no deduction under Chapter VI-A Heading 'C' (deductions for certain incomes) and no Section 10AA.

## Conditions for claiming the deduction

  • Business must not be formed by splitting up / reconstructing an existing business.
  • Must not use second-hand plant/machinery previously used for other purposes — except up to 20% of total machinery value.
  • 'Second-hand machinery' does NOT include machinery that: was not used in India before installation by the assessee; was imported from abroad; and on which no depreciation was claimed by any other assessee in any A.Y.

## Other conditions

1. Audit: Accounts must be audited by a Chartered Accountant and the report furnished in the prescribed form, signed and verified.

2. 8-year usage rule:

  • 35AD(7A): The asset must be used exclusively for the specified business for at least 8 years.
  • 35AD(7B): If put to other use within 8 years → (deduction claimed earlier − notional depreciation u/s 32) is taxed as business income of that year, and the same value is added to the block.

> Deemed income = Deduction claimed earlier − Notional Depreciation

3. Sec. 28(vii): If the 35AD asset is demolished, destroyed, discarded or transferred, any amount received/receivable is taxed as business income.

## Loss set-off [Section 73A]

Loss of a specified business (claiming 35AD) can be set off only against profits of another specified business — whether or not that other business itself claims 35AD. (Carry forward is indefinite.)

## Key definitions

  • Cold Chain Facility: chain of facilities for storage/transport of agricultural & forest produce, meat & meat products, poultry, marine & dairy products, horticulture, floriculture, apiculture and processed food, under scientifically controlled (incl. refrigeration) conditions.
  • Infrastructure Facility: roads (incl. toll roads), bridges, rail systems; highway projects incl. integral housing; water supply/treatment, irrigation, sanitation & sewerage, solid waste management; ports, airports, inland waterways, inland ports, navigational sea channels.

Worked example

### Example 1

Recapture under 35AD(7B): A cold-chain unit claimed ₹50 lakh under 35AD. After 5 years it starts using the asset for a non-specified purpose. Notional depreciation u/s 32 that would have been allowed over those years = ₹30 lakh. Deemed business income = ₹50 lakh − ₹30 lakh = ₹20 lakh, taxed in the year of diversion; ₹20 lakh is added to the block.

### Example 2

Second-hand machinery limit: A new specified-business unit has total machinery worth ₹1 crore, of which it wants to use previously-used (in India) machinery. It may use up to 20% = ₹20 lakh of such second-hand machinery and still qualify; imported machinery not earlier used in India does not count as 'second-hand'.

### Example 3

Land excluded: A hospital project (100+ beds) incurs ₹2 crore on building and ₹80 lakh on land. Only the ₹2 crore building qualifies for 35AD; the ₹80 lakh land cost does not.

⚠️ Common exam mistakes

  • Claiming 35AD on cost of land, goodwill or financial instruments — all three are excluded.
  • Allowing a company that has opted for 115BAA/115BAB to claim 35AD — it cannot.
  • Setting off a specified-business loss against ordinary business income — under Sec. 73A it can only be set off against another specified business's profits.
  • Forgetting the 8-year exclusive-use condition — diversion within 8 years triggers recapture under 35AD(7B).
  • Claiming both 35AD and a Chapter VI-A 'C' / Section 10AA deduction — once 35AD is claimed these are barred.
  • Treating imported, never-before-used-in-India machinery as disqualifying 'second-hand' machinery — it is not second-hand for this purpose.
Reference: Section 35AD
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