Section 48 · Computation of total income
Section 48 of the Income-tax Act, 2025 — Tea, Coffee and Rubber Development Account Deduction
By CA Rajat Agrawal
Updated 04 Jul 2026
Chapter IV
📜 What the law says — Section 48, Income-tax Act 2025
48. (1) Where an assessee is carrying on business of growing and manufac-
turing tea or coffee or rubber in India, such assessee shall be allowed a
deduction on the basis of deposits into the special account or deposit account
and computed as per the provisions of the Schedule IX.
(2) Any amount withdrawn or utilised or released from the aforesaid accounts at
the time of closure or otherwise shall be charged to tax as per the provisions of the
Schedule IX.
(3) Where any asset acquired as per the special scheme or the deposit scheme, as
referred to in the Schedule IX, is sold or otherwise transferred in any tax year, it
shall be charged to tax in accordance with the provisions of the said Schedule.
Site Restoration Fund.
In plain language
What Section 48 is about
Section 48 of the Income-tax Act, 2025 (effective 1 April 2026) gives a special business deduction to people and companies that both grow AND manufacture tea, coffee or rubber in India. The idea is simple: if these growers-cum-manufacturers set aside a slice of their profits into a government-approved development account, the government rewards them with a tax deduction. It is a re-investment incentive meant to keep the tea, coffee and rubber industries healthy. This provision carries forward, almost unchanged, the old Section 33AB of the Income-tax Act, 1961. In the 2025 Act the operating conditions (percentages, timelines, lock-ins) are placed in Schedule IX, while Section 48 is the short enabling section.
Who can claim it
- Only growers who also manufacture. You must be engaged in both growing and manufacturing of tea, coffee or rubber in India. A pure trader, a pure grower who sells green leaf, or a factory that buys raw leaf and only processes it does not qualify.
- Any type of assessee in this business — individual, HUF, partnership firm, LLP or company — can claim, provided the conditions are met.
- The business must be carried on in India.
How much you can deduct
The deduction is the lower of these two amounts:
- The amount actually deposited in the special/deposit account, OR
- 40% of the profits of the tea/coffee/rubber business, computed under the head "Profits and gains of business or profession" before claiming this deduction (and before set-off of brought-forward losses).
So even if you deposit more than 40% of profits, the deduction is capped at 40%.
Key conditions you must satisfy
- Where to deposit: money must go into a special account with NABARD under a scheme approved by the Tea Board, Coffee Board or Rubber Board, or into a Deposit Account under a Board-approved deposit scheme.
- By when: the deposit must be made within 6 months from the end of the tax year, or before the due date of filing the return, whichever is earlier. Miss the deadline and the deduction is lost for that year.
- Audit is compulsory: your accounts must be audited by a Chartered Accountant and the report furnished in the prescribed form along with the return. This is required even for small businesses that are otherwise below the audit threshold.
Rules on withdrawal and the 8-year asset lock-in
- Amounts can normally be withdrawn only for approved purposes (as per the Board scheme). Withdrawals are otherwise permitted only on closure of business, death of the assessee, partition of an HUF, dissolution of a firm, or liquidation of a company.
- If money is withdrawn and not used as per the scheme (misutilised), the misused amount is taxed as business income of that year.
- You cannot use the deposit to buy plant/machinery installed in a residence or guest house, office appliances (other than computers), or items eligible for 100% write-off in one year.
- 8-year lock-in: if an asset bought using these funds is sold or transferred within 8 years of acquisition, the deduction earlier allowed on that asset is clawed back and taxed as business income in the year of sale.
- No double deduction: if withdrawn money is spent on business expenses, that expenditure cannot be claimed separately again.
How it interacts with other provisions
Section 48 sits within the "Profits and gains of business or profession" chapter. Because tea/coffee/rubber income is partly agricultural and partly business, composite income rules (Rules 7, 7A, 7B, 8) apply — for tea, 40% is business income and 60% is exempt agricultural income. The Section 48 deduction is applied on the composite profit before that split. It is separate from depreciation and from general business deductions, but the same money cannot be double-counted.
Practical implications
This is a genuine deferral-plus-cap benefit for capital-intensive plantation businesses. A well-planned deposit before the return deadline can shave up to 40% off taxable plantation profit while forcing disciplined re-investment. But the audit requirement, deposit deadline and 8-year lock-in mean it must be planned with your CA well before year-end, not as an afterthought at filing time.
💡 Example
Worked example 1 — the 40% cap. Suppose Nilgiri Tea Estates Pvt Ltd earns a composite profit of ₹1,00,00,000 from growing and manufacturing tea in FY 2026-27. 40% of profit = ₹40,00,000. The company deposits ₹50,00,000 into its NABARD special account before the return due date. Deduction under Section 48 = lower of (₹50,00,000 deposited, ₹40,00,000 being 40% of profit) = ₹40,00,000. Its business profit is reduced to ₹60,00,000, of which (for tea) 40% i.e. ₹24,00,000 is taxable business income and the balance is treated as agricultural income.
Worked example 2 — deposit is the lower figure. Malabar Coffee LLP has a profit of ₹80,00,000. 40% = ₹32,00,000, but the firm only deposits ₹20,00,000 in time. Deduction = lower of (₹20,00,000, ₹32,00,000) = ₹20,00,000. The remaining ₹60,00,000 stays taxable. If two years later the LLP uses part of this deposit to buy a coffee-pulping machine and sells that machine within 8 years, the deduction attributable to it is added back as business income in the sale year.
A relatable story. Ravi runs a small rubber plantation in Kerala and also has a sheeting unit — so he both grows and manufactures. His CA tells him in February that he'll show a ₹25 lakh profit. Instead of paying full tax, Ravi deposits ₹10 lakh into the Rubber Board's NABARD scheme before filing, gets his accounts audited, and claims a ₹10 lakh deduction (below the ₹10 lakh = 40% cap). Two years later he draws that money out to buy a new roller for his factory — a permitted use — and keeps it for over 8 years, so the benefit is never reversed. He saved tax today and upgraded his unit tomorrow.
| Feature | Section 48, Income-tax Act 2025 (with Schedule IX) |
| 1961 Act equivalent | Section 33AB |
| Who qualifies | Assessee growing AND manufacturing tea, coffee or rubber in India |
| Maximum deduction | Lower of (a) amount deposited, or (b) 40% of business profits before this deduction |
| Where to deposit | NABARD special account (Board scheme) or Board-approved Deposit Account |
| Deposit deadline | Within 6 months of year-end OR before return due date, whichever is earlier |
| Audit | Compulsory CA audit; report in prescribed form filed with return |
| Asset lock-in | Asset bought with fund not to be sold within 8 years (else deduction reversed) |
| Taxable withdrawal | Misutilised / non-scheme withdrawals taxed as business income of that year |
Related sections
Section 49 — Site Restoration Fund (petroleum/natural gas) Section 33 — Depreciation on business assets Section 26 — Deductions allowed while computing business income Schedule IX — Computation rules for development account deduction Section 63 — Income of tea/coffee/rubber (composite income rules) Section 44 — Compulsory audit of business accounts
Frequently asked questions
Does Section 48 of the Income-tax Act 2025 deal with capital gains?
No. In the 1961 Act, capital gains computation was Section 48, which often causes confusion. Under the 2025 Act, Section 48 is a completely different provision — it deals with the tea/coffee/rubber development account deduction (the old Section 33AB). Capital gains rules have moved to different sections in the 2025 Act.
Can I claim Section 48 if I only grow tea but do not manufacture it?
No. You must be engaged in both growing and manufacturing tea, coffee or rubber in India. A pure grower who sells raw leaf, or a pure processor who buys raw material, is not eligible for this deduction.
What is the maximum deduction under Section 48?
The deduction is the lower of the amount actually deposited in the approved account, or 40% of the business profits computed before claiming this deduction. Even if you deposit more, the deduction is capped at 40% of profits.
By when must I deposit the money to claim the deduction?
The deposit must be made within 6 months from the end of the tax year, or before the due date for filing your income tax return, whichever is earlier. Missing this deadline means you lose the deduction for that year.
Is a tax audit compulsory to claim Section 48?
Yes. Your accounts must be audited by a Chartered Accountant and the audit report furnished in the prescribed form along with your return, regardless of your turnover. Without the audit report, the deduction is not allowed.
What happens if I sell an asset bought using the development account within 8 years?
The deduction that was earlier allowed in respect of that asset is reversed and taxed as business income in the year the asset is sold or transferred. This 8-year lock-in is meant to ensure the funds are used for genuine long-term re-investment.
Can I withdraw the deposited money whenever I want?
No. Withdrawals are permitted only for the approved scheme purposes, or on closure of business, death, partition of an HUF, dissolution of a firm, or liquidation of a company. Any amount withdrawn and not used per the scheme is taxed as business income of that year.
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.
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