HomeIncome Tax Act 2025 Business & Profession Income under the Income-tax Act, 2025 Section 32 of the Income-tax Act, 2025 — Other D...
Section 32 · Computation of total income

Section 32 of the Income-tax Act, 2025 — Other Deductions for Business and Profession

By CA Rajat Agrawal Updated 04 Jul 2026 Chapter IV
📜 What the law says — Section 32, Income-tax Act 2025
32. The following amounts shall be allowed as deduction in computing income chargeable under section 26:— (a) bonus or commission paid to an employee for services rendered, but only when such amount would not have been payable to the employee as profits or dividend if it had not been paid as bonus or commission; (b) interest paid in respect of capital borrowed for the purposes of business or profession, where— (i) such interest shall not include interest on capital borrowed for acquisition of an asset, whether capitalised in the books of account or not, for any period beginning from the date the capital was borrowed for acquisition of the asset till the date that asset was first put to use; (ii) recurring subscriptions paid periodically by shareholders or sub- scribers in Mutual Benefit Societies fulfilling the conditions as may be prescribed, shall be deemed to be capital borrowed; (c) contribution paid by a public financial institution to the credit guaran- tee fund trust for small industries as the Central Government may, by notification, specify; (d) the pro rata amount of discount on a zero coupon bond having regard to the period of life of such bond calculated in the manner, as may be prescribed, where— (i) “discount” means the difference between the amount received or receivable by the infrastructure capital company or infrastructure capital fund or public sector company or scheduled bank issuing the bond, and the amount payable on maturity or redemption of such bond; (ii) “period of life of bond” means the period commencing from the date of issue of the bond and ending on the date of the maturity or redemption of such bond; (e) the amount carried to a special reserve created and maintained by a specified entity, subject to the following conditions:— (i) such amount shall not exceed 20% of the profits derived from an eligible business computed under the head “Profits and gains of business or profession” before any deductions under this clause; and (ii) when the aggregate of such amounts carried to such reserve account from time to time exceeds twice the amount of paid-up share capital and of general r

In plain language

What Section 32 actually deals with

Section 32 of the Income-tax Act, 2025 is the "Other deductions" provision for computing profits and gains of business or profession (chargeable under Section 26). It is the modern successor to Section 36 of the old Income-tax Act, 1961. Importantly, in the 2025 Act the sprawling old Section 36 has been split up. So Section 32 does not cover everything the old Section 36 did — it is only the residual "basket" of specific allowances that did not get their own dedicated section.

Do not confuse this with the old Section 32 (1961), which dealt with depreciation. Under the 2025 Act, depreciation sits in a different section, and Section 32 (2025) is a fresh, renumbered "other deductions" clause.

The eleven allowances inside Section 32(1)

Section 32(1) lists clauses (a) to (k). Each is allowed only if the general conditions of business deductions are met:

  • (a) Bonus or commission to employees — allowed only if it is genuinely for services rendered, and would not otherwise have been payable as profit or dividend (i.e. no disguising dividends as bonus).
  • (b) Interest on borrowed capital — interest on capital borrowed for the business is deductible, but interest for the period from borrowing (for acquiring an asset) until the asset is first put to use is not allowed as revenue expense; it is capitalised.
  • (c) Credit guarantee fund contribution — contributions by public financial institutions to a notified credit guarantee fund trust for small industries.
  • (d) Zero coupon bond discount — pro-rata discount amortised over the bond's life (for infrastructure companies, scheduled banks etc.).
  • (e) Special reserve — specified financial entities (industrial/agricultural/infrastructure/housing finance) may deduct up to 20% of profits carried to a special reserve, capped once the reserve exceeds twice paid-up capital plus general reserves.
  • (f) Statutory corporation expenditure — non-capital expenditure by notified corporations set up under a Central/State Act for authorised objects.
  • (g) Sugarcane purchase — expenditure by co-operative sugar factories on cane bought at government-fixed/approved price.
  • (h) Marked-to-market / expected losses — computed as per the notified Income Computation and Disclosure Standards (ICDS).
  • (i) Family planning expenditure — revenue expenditure by a company is fully deductible; capital expenditure gets one-fifth in the year and the balance over the next four years.
  • (j) Animal loss — where animals used for business (not stock-in-trade) die or become permanently useless, the difference between cost and carcass realisation is deductible.
  • (k) STT / CTT — Securities Transaction Tax or Commodities Transaction Tax paid, where the related income is taxed as business income.

Who it applies to

Anyone taxable under the head "Profits and gains of business or profession" — sole proprietors, partnership firms, LLPs, companies, co-operatives and financial institutions — can claim the clauses that fit their facts. A salaried employee or a person with only house-property or capital-gains income cannot use Section 32.

How it interacts with the neighbouring sections

Because the old Section 36 was broken apart, the items people most commonly look for are now elsewhere:

  • Employer/employee fund contributions (recognised PF, approved superannuation, gratuity, pension/NPS, ESI welfare funds — with the strict "credit before due date" rule for employees' contributions) are dealt with under Section 29.
  • Insurance premiums — on stock/stores against fire/damage, health of employees, and cattle/livestock — are under Section 30.
  • Bad debts and provision for bad and doubtful debts are under Section 31.
  • General conditions for allowability sit in the surrounding sections and in Section 34 (general deduction) and the disallowance rules.

Practical implications

The key practical takeaway is renumbering, not a change in the underlying tax logic. If your accountant earlier claimed something under "Section 36(1)", from 1 April 2026 it may live under Section 29, 30, 31 or 32 depending on the item. Always check that (i) the expense is genuinely for the business, (ii) it is not personal or capital in nature unless a clause specifically permits it, and (iii) statutory timing conditions (like the borrowed-capital "put to use" rule and the reserve caps) are respected. Keep documentation — board resolutions for bonus, loan sanction letters and interest certificates, reserve computations, and STT/CTT contract notes.

💡 Example

Example 1 — Interest on borrowed capital (clause b): Sharma Textiles Pvt Ltd borrows ₹50,00,000 on 1 April 2026 at 12% p.a. to buy a new loom. The loom is installed and first used on 1 October 2026. Interest for 1 April to 30 September (6 months = ₹3,00,000) relates to the pre-use period and must be capitalised (added to the asset's cost, giving depreciation later). Interest from 1 October 2026 to 31 March 2027 (₹3,00,000) is a revenue deduction under Section 32(1)(b). So the company claims ₹3,00,000 as an interest expense this year, not the full ₹6,00,000.

Example 2 — Family planning expenditure (clause i): A company spends ₹10,00,000 building a family-planning awareness centre for its factory workers (capital expenditure). Under Section 32(1)(i), it deducts one-fifth = ₹2,00,000 in the year of spending, and ₹2,00,000 in each of the next four years. Any purely revenue expense (say ₹50,000 on counselling camps) is fully deductible in the same year.

A relatable story: Meera runs a small trading firm. Her accountant used to file everything under "Section 36" — interest on her business loan, staff bonuses, the STT on her firm's share trades, and PF contributions. When the 2025 Act kicked in from April 2026, she panicked seeing new section numbers on her computation. Her CA reassured her: the bonus, loan interest and STT are now under Section 32, the PF contribution moved to Section 29. Nothing she could claim before was lost — only the labels changed. Her tax outcome stayed exactly the same.

Deduction itemOld Act (1961)New Act (2025)Key condition / limit
Bonus / commission to employeesSec 36(1)(ii)Sec 32(1)(a)For services; not a disguised dividend/profit
Interest on borrowed capitalSec 36(1)(iii)Sec 32(1)(b)Pre-"put to use" interest on asset capitalised
Special reserve (finance entities)Sec 36(1)(viii)Sec 32(1)(e)Up to 20% of profits; cap at 2× (capital + general reserves)
Family planning expenditure (company)Sec 36(1)(ix)Sec 32(1)(i)Capital: 1/5th now + balance over 4 years
STT / CTT paidSec 36(1)(xv)/(xvi)Sec 32(1)(k)Related income taxed as business income
Employer/employee fund contributions (PF, gratuity, ESI, NPS)Sec 36(1)(iv)/(iva)/(v)/(va)Sec 29 (not 32)Employees' share credited before due date
Insurance premium (stock, health, cattle)Sec 36(1)(i)/(ia)/(ib)Sec 30 (not 32)Business insurance; health via approved mode
Bad debts / provision for doubtful debtsSec 36(1)(vii)/(viia)Sec 31 (not 32)Written off in books; banks have separate limits

Related sections

Section 26 — Income chargeable as profits and gains of business or profession Section 29 — Employer and employee contributions to PF, gratuity, superannuation and welfare funds Section 30 — Deduction for insurance premiums (stock, employee health, cattle) Section 31 — Deduction for bad debts and provision for bad and doubtful debts Section 28 — Rent, rates, taxes, repairs and depreciation of business premises Section 34 — General deduction for business expenditure (residual)

Frequently asked questions

Is Section 32 of the 2025 Act about depreciation like the old Section 32 of 1961?
No. Under the 1961 Act, Section 32 was depreciation. In the Income-tax Act, 2025, Section 32 is renamed 'Other deductions' and corresponds to the old Section 36. Depreciation has been moved to a different section number in the new Act.
Which old section does Section 32 (2025) replace?
It replaces Section 36 of the Income-tax Act, 1961 — the 'other deductions' provision. However, the 2025 Act split the old Section 36, so PF/insurance/bad-debt items moved to Sections 29, 30 and 31 respectively.
Can I claim my business loan interest under Section 32?
Yes, interest on capital borrowed for the business is deductible under Section 32(1)(b). But if the loan was taken to acquire an asset, interest for the period before the asset is first put to use must be capitalised, not claimed as a current expense.
Where do employer PF and gratuity contributions go now?
Employer contributions to recognised provident, approved superannuation, gratuity and notified pension funds are now dealt with under Section 29 of the 2025 Act, not Section 32. Employees' contributions must still be deposited before the due date to be allowed.
Is STT paid by a trader deductible under Section 32?
Yes. Section 32(1)(k) allows Securities Transaction Tax or Commodities Transaction Tax as a business deduction, provided the income from those transactions is taxed under the business-and-profession head.
How is a company's family planning expenditure treated?
Revenue expenditure on promoting family planning among employees is fully deductible in the year incurred. Capital expenditure is spread out — one-fifth is allowed in the year of spending and the balance in equal parts over the next four years, under Section 32(1)(i).
Does Section 32 apply to salaried individuals?
No. Section 32 only applies to taxpayers computing income under 'profits and gains of business or profession'. Salaried employees and those with only house property or capital-gains income cannot claim under it.
C
CA Rajat Agrawal
Chartered Accountant, EaseValue · Reviewed 04 Jul 2026
This explainer is prepared and reviewed by EaseValue's tax team, based on the text of the Income-tax Act, 2025 (as amended by the Finance Act, 2026).
Disclaimer: This page explains the law in general terms for education and is not professional advice. The Income-tax Act, 2025 takes effect from 1 April 2026; provisions, thresholds and interpretations may change. Please confirm your specific position with our team before acting.

💬 Discussion & questions

0 comments · Ask anything about this — a Chartered Accountant or the community will reply.

Have a doubt about this (Section 32)? Ask here 👇
Free · takes 20 seconds · our CA answers. No account needed.
Your name
Email (optional)
4 + 3 = ?
Posts appear after a quick moderation check. General information, not professional advice.
No comments yet — be the first to ask. 👆

Have a question on this?

Ask our CA how Section 32 applies to you.

💬 Ask our CA Browse the full Act →
💬