Running a business means dealing with dozens of expenses that don’t fit neatly into rent, salaries, or depreciation. What about the premium you pay to insure your shop’s stock against fire? Or the provident fund contribution you deposit every month for your staff? The Income Tax Act has a dedicated basket for these: Section 36, often labelled “Other Deductions” in commerce textbooks. It lists specific business expenses that Parliament has expressly allowed as deductions while computing profits and gains of business or profession, and knowing them well is central to any income tax paper in a B.Com course.

This guide walks through each deduction under Section 36 in the sequence commonly taught, explains the conditions attached to each, and gives practical examples so the concepts stick.

Table of Contents

Why section 36 exists

Section 28 to 44 of the Income Tax Act, 1961 collectively define how “profits and gains of business or profession” are computed. While Sections 30 to 35 deal with rent, repairs, depreciation, and scientific research, Section 36 lists a separate set of allowable expenses ranging from insurance premiums to bad debts. These are specific, meaning each clause has its own conditions, and an expense must satisfy those conditions exactly to qualify. If it doesn’t fit any clause of Section 36, a business can still try to claim it as a general deduction under Section 37, provided it is incurred wholly and exclusively for business purposes.

Insurance premiums as a deductible expense

Section 36(1)(i) and its related sub-clauses allow deductions for three types of insurance premiums, and each has a distinct purpose.

Insurance on stock-in-trade

Businesses that hold high-value inventory, jewellers, textile traders, electronics dealers, often insure their stock against fire, theft, or flood damage. The premium paid for this cover is fully deductible as a business expense. The logic is simple: protecting the very asset that generates business income is itself a cost of doing business.

Insurance on the life of cattle

This is a narrower provision aimed at dairy cooperatives. If a federal milk cooperative society pays a premium to insure the cattle owned by members of its affiliated primary societies, that premium is deductible. This clause specifically supports the cooperative dairy model that is common in states like Gujarat and Maharashtra, where primary societies supply milk to a federal cooperative structure.

Health insurance for employees

Employers who provide group health insurance to their employees can deduct the premium paid, but with one important condition: the payment must be made through any mode other than cash. A cheque, bank transfer, UPI, or card payment qualifies; handing over cash does not. This condition pushes businesses toward traceable, formal payment channels, and it is a favourite exam question because students often forget the “non-cash” rider.

Bonus and commission to employees

Under Section 36(1)(ii), any bonus or commission paid to employees for services rendered is deductible, including both statutory bonus (governed by the Payment of Bonus Act) and voluntary bonus paid at the employer’s discretion. There are two conditions to keep in mind:

  • Not in lieu of dividend: If a company pays its employee-shareholders a “bonus” that is really a disguised dividend distribution, it cannot be claimed as a deduction.
  • Section 43B compliance: Bonus and commission are deductible only in the year they are actually paid, not merely provided for in the books. If unpaid at year-end, the deduction shifts to the year of actual payment.

Interest on borrowed capital

Section 36(1)(iii) allows a deduction for interest paid on capital borrowed for business or professional purposes. This is one of the most frequently tested provisions because of a specific carve-out: if the borrowed funds are used to acquire an asset, interest paid for the period from the date of borrowing until the date the asset is actually put to use cannot be claimed as a revenue deduction. Instead, that interest is capitalised, added to the cost of the asset, and recovered gradually through depreciation. Only interest relating to the period after the asset starts being used qualifies as a straightforward deduction.

For example, if a manufacturing unit borrows money in April to install machinery, and the machinery starts running only in October, the interest for April to September gets added to the machinery’s cost, while interest paid from October onward is deducted directly against that year’s profits.

Discount on zero coupon bonds

A zero-coupon bond (ZCB) does not pay periodic interest. Instead, it is issued at a discount and redeemed at face value, with the difference representing the investor’s return. Section 36(1)(iiia) allows the issuing company to deduct this discount, but not all at once. The discount is amortised, or spread out, over the life of the bond on a pro-rata basis. This matches the accounting principle that expenses should be recognised in the period they relate to, rather than dumped entirely into the year of issue.

Contributions to provident and superannuation funds

Employer contributions to a recognised provident fund or an approved superannuation fund are deductible business expenses. Two features define this deduction:

Payment basis, not accrual

The deduction is allowed only in the year the contribution is actually deposited with the fund, not merely when it becomes due in the books of account. This aligns with Section 43B, which converts several statutory dues, provident fund contributions included, from an accrual basis to a payment basis for deduction purposes.

Employees’ own contributions

A related provision, Section 36(1)(va), deals with the employee’s share of provident fund or ESI contribution that the employer deducts from salary and holds in trust before depositing it with the relevant authority. This amount must be deposited within the due date specified under the respective welfare legislation, for instance, the 15th of the following month for EPF. Miss that due date, and the deduction is denied outright, even if the amount is deposited later in the same financial year. This is a stricter rule than the one for the employer’s own contribution and is a common source of litigation and disallowance in tax assessments.

Bad debts written off

Section 36(1)(vii) permits a deduction for any debt, or part of a debt, that becomes irrecoverable during the year and is written off in the books of account. The conditions, as clarified through statutory language and judicial interpretation, are fairly specific:

  • The debt must have arisen in the ordinary course of business, such as unpaid trade receivables from a customer.
  • It must have been previously offered to tax, meaning the amount was already included in the business’s income in an earlier year, or it represents money lent in the ordinary course of a money-lending business.
  • Actual write-off in the accounts is mandatory. A mere provision or estimate for doubtful debts is not enough; the amount must be removed from the “debtors” account, since a general provision does not satisfy this clause, as only debts directly connected to the business and formally written off qualify.
  • Capital advances don’t count. If a business advances money to buy an asset like property, and that advance later turns bad, it cannot be claimed under this clause because it was never a trading debt.

Banks and certain financial institutions follow a slightly different regime under Section 36(1)(viia), which allows a deduction for a provision for bad and doubtful debts, in addition to the write-off allowed under clause (vii). This distinction exists because banking businesses carry large loan books where provisioning is a regulatory requirement under RBI norms.

A quick reference table

Deduction Relevant clause Key condition
Insurance on stock-in-trade 36(1)(i) Premium must relate to business stock
Insurance on cattle 36(1)(i) (federal milk society) Paid by a federal milk cooperative society
Health insurance for employees 36(1)(ib) Payment in any mode other than cash
Bonus or commission 36(1)(ii) Not in lieu of dividend; paid, not merely provided
Interest on borrowed capital 36(1)(iii) Pre-use interest is capitalised, not deducted
Discount on zero coupon bonds 36(1)(iiia) Amortised over the bond’s tenure
Employer’s PF/superannuation contribution 36(1)(iv), (v) Deductible on payment basis
Employees’ PF/ESI contribution 36(1)(va) Must be deposited by the due date under the relevant Act
Bad debts written off 36(1)(vii) Must be an actual write-off of a genuine trade debt

Why this matters beyond the exam hall

These provisions aren’t just theoretical clauses to memorise for a tax paper. Every one of them shapes real decisions: whether a company times its asset purchases carefully, whether an HR team pushes payroll processing to hit provident fund deadlines, or whether a finance manager decides to write off a stale receivable before the financial year closes. Understanding the conditions attached to each deduction is what separates a business that legitimately reduces its tax outgo from one that ends up with disallowances and penalty interest after an assessment.

What do you think? If a business delays depositing an employee’s provident fund contribution by even a week past the due date, should the deduction be denied entirely, or should there be some room for genuine delays? And between capitalising pre-use interest versus expensing it immediately, which approach do you think gives a fairer picture of a company’s yearly profits?

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References
  1. https://www.incometaxindia.gov.in/w/section-36-24
  2. https://cleartax.in/s/section-36-deductions-income-tax-act
  3. https://www.coverfox.com/personal-finance/tax/section-36-deductions/
  4. https://tax2win.in/guide/section-36-deductions
  5. https://www.adityabirlacapital.com/abc-of-money/section-36-deductions-in-income-tax
  6. https://carajput.com/blog/deduction-for-bad-debts-explanation-of-section-361vii/

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Income Tax Law and Practice

1 Basic Concepts-I

  1. Broad Mechanism of Income Tax in India
  2. Concept of Income
  3. Definition of Person
  4. Definition of Assessee
  5. Permanent Account Number
  6. Assessment Year
  7. Previous Year
  8. Taxation of Previous Year’s Income during the Same Year
  9. Concept of Total Income
  10. Accounting Method

2 Basic Concepts-II

  1. Agricultural Income
  2. Definition of Agricultural Income
  3. Kinds of Agricultural Income
  4. Instances of Non-agricultural Income
  5. Partly Agricultural Income
  6. Integration of Agricultural Income with Non-agricultural Income
  7. Concept of Casual Income
  8. Examples of Casual Income
  9. Incomes Not Treated as Casual Income
  10. Capital and Revenue Receipts
  11. Determine the Nature of a Receipt
  12. Examples of Capital and Revenue Receipts

3 Residential Status and Tax Liability

  1. Importance of Residential Status
  2. Categories of Residential Status
  3. Rules for Determining Residential Status
  4. Scope of Total Income on the Basis of Residence
  5. Kinds of Incomes
  6. Income Received in India
  7. Income Deemed to be Received in India
  8. Incomes Accruing or Arising in India
  9. Income Deemed to Accrue or Arise in India
  10. Incidence of Tax

4 Exempted Incomes

  1. Meaning of Exempted Income
  2. List of Exempted Incomes
  3. Certain Exempted Incomes in the Hands of an Individual
  4. Exempted Incomes of Certain Institutions and Funds
  5. Income of Charitable and Religious Trusts and Political Parties
  6. Exempted Income for Non-Citizen And/or Non-Resident Assessee

5 Salaries-I

  1. Meaning of Salary
  2. Some Important Points Regarding Salary
  3. Definition of Salary for Different Purposes
  4. Salary or Wages
  5. Encashment of Earned Leave on Retirement
  6. Bonus, Fees, Commission, Profit in Lieu of Salary
  7. Pension
  8. Annuity
  9. Gratuity
  10. Compensation on Retrenchment
  11. Voluntary Retirement
  12. Advance Salary

6 Salaries-II

  1. Perquisites
  2. Valuation of Perquisites for Specified Employees
  3. Fully Exempted Perquisites (Tax Free Perquisites)
  4. Deduction from ‘Salaries’

7 Salaries-III

  1. Provident Fund Schemes
  2. Statutory Provident Fund
  3. Recognized Provident Fund
  4. Unrecognized Provident Fund
  5. Public Provident Fund (PPF)
  6. Approved Superannuation Fund
  7. Tax Treatment of Provident Fund
  8. Certain Other Aspects of Taxable Salary
  9. Deduction under Section 80C
  10. Gross Qualifying Amount

8 Income from House Property

  1. Income from House Property
  2. Exempted Incomes from House Property
  3. Some Important Points
  4. Annual Value
  5. Computation of Annual Value
  6. Deductions from Annual Value
  7. Loss under the Head ‘Income from House Property’
  8. Computation of Taxable Income from House Property

9 Income from Profits and Gains of Business or Profession-I

  1. Meaning of Business or Profession or Vocation
  2. Basis of Charge
  3. General Principles for Calculating Business and Profession Income
  4. Computation of Income from Business or Profession
  5. Specific Deductions-I: Rent, Rates, Taxes, Repairs, and Insurance for Buildings
  6. Repairs and Insurance of Machinery, Plant & Furniture
  7. Depreciation
  8. Incentive for Acquisition and Installation of New Plant or Machinery in the Notified Backward Areas in Certain States

10 Income from Profits and Gains of Business or Profession-II

  1. Tea Development Account, Coffee Development Account and Rubber Development Account
  2. Site Restoration Fund
  3. Expenditure on Scientific Research
  4. Amortisation of Spectrum Fee for Purchase of Spectrum
  5. Amortisation of Telecom License Fees
  6. Deduction in Respect of Expenditure on Specified Business
  7. Expenditure by Way of Payments to Association and Institutions for Carrying Out Rural Development Programmes
  8. Weighted Deduction of 100% for Expenditure Incurred on Agricultural Extension Project
  9. Weighted Deduction of 100% for Expenditure Incurred by a Company on Skill Development Project
  10. Amortization of Certain Preliminary Expenses
  11. Amortization of Expenditure in Case of Amalgamation or Demerger
  12. Amortization of Expenditure Incurred Under Voluntary Retirement Scheme
  13. Other Deductions
  14. General Deductions

11 Income from Profits and Gains of Business or Profession-III

  1. Special Disallowances under the Act
  2. Deemed Profits Chargeable to Tax
  3. Maintenance of Books of Account
  4. Compulsory Audit of Accounts
  5. Estimated Income Method for Computing Business Income

12 Capital Gains

  1. Concept of Capital Asset
  2. Transfer of Capital Asset
  3. Computation of Capital Gains
  4. Cost of Acquisition
  5. Cost of Improvement
  6. Indexed Cost of Acquisition and Improvement
  7. Capital Gains Exempt from Tax
  8. Tax on Short term capital gain on Transfer of Equity Shares
  9. Tax on Long Term Capital Gain on Transfer of Listed Securities
  10. Computation of Taxable Income from Capital Gains

13 Income from other Sources

  1. Income Chargeable Under the Head Income from Other Sources
  2. Deductions Allowed
  3. Dividends
  4. Winnings from Lotteries, Crossword Puzzles, Horse Races, Card Games, etc. (Casual Incomes)
  5. Interest on Securities
  6. Income from Letting out of Plant, Machinery or Furniture
  7. Income from Composite Letting of Machinery, Plant, Furniture and Building
  8. Contributions Received from Employees
  9. Receipts without Consideration
  10. Family Pension Received by the Legal Heirs of a Deceased Employee
  11. Receipt of Shares by a Firm or a Company
  12. Share Premium in Excess of Fair Market Value
  13. Interest on Compensation or on Enhanced Compensation

14 Aggregation of Incomes (Clubbing of Incomes and Deemed Incomes) and Set off and Carry Forward of Losses

  1. Aggregated Income
  2. Deemed Incomes
  3. Clubbing of Incomes
  4. Income of Minor Child
  5. Income from Converted Property
  6. Income from the Accretion to Assets
  7. Clubbing of Negative Incomes
  8. Set off and Carry Forward of Losses
  9. Inter-source adjustment
  10. Inter-Head adjustment
  11. Set off of losses of General Business
  12. Set off of losses of Speculation Business
  13. Set off of losses of Specified Business
  14. Set off of losses under the head Capital Gains
  15. Set off of losses from Owning and Maintaining Race Horses
  16. Set off of losses of Lottery, Betting, Gambling, Cross Word, Puzzles or Card Games

15 Deductions from Gross Total Income

  1. Deductions to Encourage Savings
  2. Deductions for Certain Personal Expenditure
  3. Deductions for Encouraging Voluntary Participation in Charitable and Socially Desirable Activities
  4. Deductions for Economic Growth
  5. Deductions in Respect of Royalty Income
  6. Deduction in Respect of Saving Bank A/C Interest
  7. Deduction in Case of Person with Disability

16 Assessment of Individuals

  1. Steps in Computation of Total Income
  2. Head wise Computation of Income
  3. Computation of Gross Total Income
  4. Deductions under Chapter VIA
  5. Some Illustrations (Computation of Total Income)
  6. Computation of Tax Liability of Individuals (with Illustrations)

17 Assessment of Firms

  1. Meaning and Definition of Partnership
  2. Essential Features of Partnership Firm
  3. Partnership Deed/Deed of Partnership
  4. Registration of Firm
  5. Non-Registration of Firm
  6. General Rules and Procedure
  7. Provisions of Section 184 Regarding Assessment of Firm
  8. Assessment in Case of Non-Compliance of Section 184
  9. Provisions of Section 40 (B) Regarding Assessment of Firm
  10. Computation of Book Profit
  11. Computation of Total Income of the Firm
  12. Computation of Tax Liability of the Firm
  13. Provisions of Alternate Minimum Tax (AMT) For Limited Liability Partnerships (LLP)
  14. Computation of Partner’s Income from The Firm
  15. Assessment of Reconstituted Firm
  16. Assessment in Case of Succession of One Firm by Another Firm
  17. Joint and Several Liabilities of Partners for Tax Payable by Firm
  18. Dissolution of A Firm or Discontinuance of Business
  19. Procedure of Tax Payment and Filing of Return of Income by Firms

18 Filing of Return and Tax Authorities

  1. Return of Income
  2. Submission of Return of Income [Section 139(1)]
  3. Due Dates for Filing the Return
  4. Central Government Empowered to Exempt any Person from the Requirement of Furnishing Return of Income [Section 139(1c)]
  5. Permanent Account Number (PAN) [Section 139(a)]
  6. Quoting of Aadhar Number [Section 139(aa)]
  7. New Scheme to Facilitate Submission of Returns through Tax Return Preparers [Section 139(b)]
  8. Selection of Correct Form of Return [Rule 12]
  9. Belated Return [Section 139(4)]
  10. Revised Return [Section 139(5)]
  11. Defective Return [Section 139(9)]
  12. Power of Board to Dispense with Furnishing Documents etc with the Return [Section 139(c)]
  13. Return of Losses [Section 139(3)]
  14. Types of Assessment
  15. E-Filing of Return [Section 139(d)]
  16. Tax Authorities
  17. Verification of Return [Section 140]
  18. Consequences of Delay in Filing Return
  19. Consequences of Incorrect Information

19 Online Filing of Returns

  1. What is Income Tax Return (ITR)?
  2. Documents required for filing ITR
  3. Advantages of filing ITR
  4. Benefits of E-Filing over Physical Filing of Returns
  5. Step to step guide for E-filing of returns
  6. Do’s and Don’ts of E-filing of Returns

20 Leading Cases Decided by Supreme Court

  1. Analysis of Bharat V. Patel Judgment, 2018 (Income from Salaries)
  2. Surya Roshni Ltd Vs. EPFO, 2019 LLR 339 (Provident Contribution on all Allowances)
  3. CIT Vs. Podar Cement (P) Ltd (House Property)
  4. Universal Plast Ltd. Vs. CIT (Income Earned by the Assessee by Leasing out Assets of Business)
  5. Shivakumar Kheny (HUF) v. ITOITA No. 792/Bang/2019 (Capital Gain)
  6. CIT vs. O. K. Arumugham Chettiar & Anr (Income from other sources)
  7. CIT v. M.R. Doshi 211 ITR 1 (Clubbing of Income)
  8. Quoting Aadhaar Mandatory for Filing Income Tax Returns and PAN Application