Vinita Bio-medicals Ltd. is engaged in the business of manufacture of biomedical items. The following expenses were incurred in respect of activities connected with Scientific Research : Year Ended Particulars Amount (₹)

CS Professional · Goods and Services Tax (GST) and Corporate Tax Planning · PYQS · June 2025
Vinita Bio-medicals Ltd. is engaged in the business of manufacture of biomedical items. The following expenses were incurred in respect of activities connected with Scientific Research : Year Ended Particulars Amount (₹) 30.04.2021 Land 16,00,000 30.04.2021 Building 25,00,000 31.01.2024 Plant and Machinery 5,00,000 31.03.2023 Raw Materials 2,20,000 31.03.2025 Raw Materials and Salaries 1,80,000 The business was commenced on 01.09.2024. In view of availability of better model of Plant & Machinery, the existing Plant & Machinery were sold for ₹16,00,000 on 01.03.2025. Discuss the implications of the above for AY 2025-2026 along with brief computation of deduction permissible u/s 35, assuming that necessary conditions have been fulfilled. You are informed that the assessee's line of business is eligible for claiming deduction u/s 35/35(2AB).

Answer & Explanation:

Answer 6A(i) Computation of Deduction permissible u/s 35 Nature of Expenditure Actual Expenses % of Deduction Deductible Amount Land - Land is not entitled for deduction. 16,00,000 - - Building acquired in the preceding 3 years before date of commencement business is only eligible as deduction in FYs. As building has been acquired on 30.04.2021 i.e. before the preceding 3 years from the date of commencement of business i.e. 01.09.2024 and therefore not eligible for deduction. 25,00,000 0% Nil Plant and Machinery 100% deduction of Current year Revenue or Capital Expenditure on Scientific Research is allowed under section 35(1)(iv) 5,00,000 100% 5,00,000 Raw Materials acquired in the preceding year Prior Period Revenue Expenditure incurred for Raw Materials or Salary during 3 years immediately preceding the date of commencement of business, will be allowed as deduction in the previous year in which the assessee commenced the business 2,20,000 100% 2,20,000 Current Year exp. on Raw Materials & Salaries 100% deduction of Current year Revenue or Capital Expenditure on Scientific Research is allowed under section 35(2AB) 1,80,000 100% 1,80,000 Total Deduction for the Previous Year 2024-25 9,00,000 Consequence of Sale of Capital Asset: As per the provision of sections 41(3) of the Income tax Act, 1961, where a Capital Asset used for Scientific Research is sold without introducing the same into the business, the Sale Proceeds of the asset, up to the amount of deduction claimed shall be treated as Business Income of the Previous Year in which such transfer took place. Any excess amount shall be taxed under the head Capital Gains. In this case, Amount of Short-Term Capital Gains u/s 45 = Total Sale Consideration Less Deduction Allowed = ₹16,00,000 - ₹5,00,000 = ₹11,00,000. Business Income u/s 41(3) = ₹5,00,000

Topics: Corporate Tax Planning

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