Business Income — PGBP, Depreciation, and Presumptive Taxation
How to compute Profits and Gains of Business or Profession — from P&L adjustments and Section 37 to the block-of-assets depreciation method and the presumptive schemes under Sections 44AD and 44ADA. Applied to Sunrise Retail Pvt Ltd FY 2025-26.
Module 4 of 7 — Income Tax & ITR. This lesson covers business income computation — the P&L-to-taxable-income journey for Sunrise Retail Pvt Ltd, block-of-assets depreciation, and when presumptive taxation applies. Duration: 55 minutes.
Learning Objectives
- Understand why accounting profit ≠ taxable business income and how IT adjustments bridge the gap
- Apply Section 37 (general deductions), Section 40(a) (TDS disallowance), Section 40A(3) (cash payment), and Section 43B (actual payment basis) correctly
- Compute depreciation under the Income Tax block-of-assets WDV method
- Determine eligibility for presumptive taxation under Section 44AD or 44ADA
- Build the complete PGBP computation for Sunrise Retail Pvt Ltd for FY 2025-26
What Is PGBP?
Profits and Gains of Business or Profession (PGBP) captures all income from carrying on any trade, commerce, manufacture, or profession. The starting point for computation is the net profit per the books of account (P&L account), adjusted by adding back inadmissible expenses and excluding non-business receipts.
The result is the taxable business income charged to tax.
Section 37 — The General Deduction Rule
Section 37(1) is the foundation of all business deductions:
Any expenditure laid out or expended wholly and exclusively for the purpose of business or profession shall be allowed — provided it is not of a capital nature, not a personal expense, and not specifically prohibited elsewhere.
Three tests:
- Revenue — not capital (buying machinery is capital; servicing it is revenue)
- Wholly and exclusively — for the business; personal element disqualifies it
- Not specifically prohibited — some payments are disallowed regardless of purpose
Common deductible expenses under Section 37: advertising, rent, repairs, insurance, professional fees, staff salaries, interest on business loans, office expenses.
Section 37(2B) — CSR Expenditure Not Deductible
Expenditure on corporate social responsibility under Section 135 of the Companies Act is not deductible under Section 37. It must be added back to net profit.
Section 40(a) — TDS Disallowance
If a payment requires TDS (rent, professional fees, contractor payments) and TDS was not deducted or not deposited, 30% of the payment is disallowed in the year of payment.
Example: Sunrise Retail pays ₹1,50,000 professional fees to its CA firm without deducting TDS under Section 194J. Disallowance = 30% × ₹1,50,000 = ₹45,000.
The disallowance reverses in the year TDS is eventually deposited — it is a timing issue, not a permanent loss.
Section 40A — Related Party and Cash Payments
Section 40A(2) — Related Party Payments
Payments to related parties (directors, shareholders ≥20%, relatives) at prices above market rate are disallowed to the extent of the excess.
Sunrise Retail example: If the company pays ₹15,000/month rent to Kiran Sharma (its director) for office space when the market rent for equivalent space is ₹10,000/month, the excess ₹5,000/month = ₹60,000/year may be disallowed under Section 40A(2).
Section 40A(3) — Cash Payment Limit
Any single payment exceeding ₹10,000 in cash (₹35,000 for transporters) is 100% disallowed. Payments must be made by account payee cheque, RTGS, NEFT, or approved electronic mode.
Section 43B — Actual Payment Basis
Certain expenses are deductible only when actually paid, regardless of the accrual method used in the books:
| Expense | Section | Rule |
|---|---|---|
| GST (CGST, SGST, IGST) | 43B(a) | Deductible only in year of actual payment to government |
| Employer PF, ESI contributions | 43B(b) | Must be paid before the due date for the fund |
| Bonus, leave encashment | 43B(d) | Deductible only when paid |
| Interest on loans from financial institutions | 43B(e) | Deductible when paid |
Key implication: If Sunrise Retail has outstanding GST of ₹3,50,000 as at 31 March 2026 not yet paid, that amount cannot be claimed as a deduction in FY 2025-26.
Depreciation Under the Income Tax Act — Section 32
Income Tax uses a different method and different rates from company law. For tax purposes, depreciation is always WDV (Written Down Value) method — declining balance.
Block of Assets Concept
Assets are not tracked individually. All assets of the same class and rate are grouped into a block. Opening WDV + additions − disposal proceeds = adjusted WDV. Depreciation is computed on this adjusted WDV.
Standard Depreciation Rates
| Block | IT Rate |
|---|---|
| Buildings — residential | 5% |
| Buildings — non-residential | 10% |
| Furniture and fittings | 10% |
| Plant and machinery — general | 15% |
| Computers and data-processing equipment | 40% |
| Motor vehicles (not for hire) | 15% |
| Intangibles (patents, trademarks, copyrights) | 25% |
Half-Year Convention
If an asset is acquired and put to use for fewer than 180 days in a financial year (i.e. in the second half — October onwards), only 50% of normal depreciation is allowed in that year.
Additional Depreciation — Section 32(1)(iia)
For new plant or machinery acquired by a manufacturing business, an additional 20% depreciation is allowed in the first year. Electronics trading (Sunrise Retail) does not qualify — this benefit is restricted to manufacturing.
Depreciation Computation — Sunrise Retail (FY 2025-26)
Fixed assets as at 1 April 2025:
| Block | Opening WDV | Additions | Disposal | IT Rate | Depreciation | Closing WDV |
|---|---|---|---|---|---|---|
| Office computers | ₹1,20,000 | ₹80,000 (May 2025 — first half) | — | 40% | ₹80,000* | ₹1,20,000 |
| Furniture | ₹2,40,000 | — | — | 10% | ₹24,000 | ₹2,16,000 |
| Motor vehicle | ₹4,50,000 | — | — | 15% | ₹67,500 | ₹3,82,500 |
| Total | ₹8,10,000 | ₹80,000 | ₹1,71,500 | ₹7,18,500 |
*Computer block: Opening WDV ₹1,20,000 + addition ₹80,000 = ₹2,00,000 × 40% = ₹80,000. Addition put to use in May 2025 (first half of FY — full year depreciation applies).
Total IT depreciation = ₹1,71,500
Business Income Computation — Sunrise Retail Pvt Ltd (FY 2025-26)
Summarised P&L Account
| Item | Amount |
|---|---|
| Revenue from operations (electronics sales) | ₹2,80,00,000 |
| Less: Cost of goods sold | (₹2,24,00,000) |
| Gross Profit | ₹56,00,000 |
| Less: Salaries and wages | ₹12,00,000 |
| Less: Rent (warehouse + office) | ₹6,00,000 |
| Less: Electricity | ₹1,20,000 |
| Less: Advertising | ₹2,40,000 |
| Less: Repairs and maintenance | ₹80,000 |
| Less: Professional fees (CA, legal) | ₹1,50,000 |
| Less: Depreciation (as per books, SLM) | ₹2,40,000 |
| Less: Miscellaneous expenses | ₹70,000 |
| Total Expenses | ₹27,00,000 |
| Net Profit before tax (as per P&L) | ₹29,00,000 |
Income Tax Adjustments
| Adjustment | Add / (Deduct) |
|---|---|
| Add: Depreciation per books (reversal) | +₹2,40,000 |
| Deduct: Depreciation per IT — Section 32 | (₹1,71,500) |
| Add: TDS on professional fees not deducted — 30% of ₹1,50,000 | +₹45,000 |
| Add: Cash payment >₹10,000 in miscellaneous expenses | +₹20,000 |
| Add: GST outstanding at 31 March 2026 not paid — Section 43B | +₹35,000 |
| Net adjustments | +₹1,68,500 |
Taxable Business Income (PGBP)
| Amount | |
|---|---|
| Net profit as per P&L | ₹29,00,000 |
| Add: Net IT adjustments | ₹1,68,500 |
| Business income (PGBP) — Sunrise Retail | ₹30,68,500 |
Corporate tax: ₹30,68,500 × 25.17% (Section 115BAA effective rate) = approximately ₹7,72,341.
Presumptive Taxation — Sections 44AD and 44ADA
Section 44AD — For Small Businesses
| Feature | Detail |
|---|---|
| Who qualifies | Resident individual, HUF, or partnership firm only |
| Turnover limit | ≤ ₹3,00,00,000 (₹3 crore) — enhanced for businesses with ≥95% digital receipts |
| Presumed profit | 8% of gross turnover; 6% for receipts via banking/digital channels |
| Records needed | None — no books of account required |
| Advance tax | All in one instalment by 15 March |
Does Section 44AD apply to Sunrise Retail Pvt Ltd?
No — for two reasons:
- Entity type: 44AD covers only resident individuals, HUF, and partnership firms. Companies are excluded.
- Even if Sunrise Retail were an individual, its ₹2.80 crore turnover is below ₹3 crore — it would qualify on turnover, but the entity type disqualifies it.
Kiran's proprietorship — Kiran Electronics: If Kiran Electronics has ₹1,20,00,000 (₹1.2 crore) turnover in FY 2025-26 with 80% digital receipts, Kiran could opt for 44AD:
- Digital receipts: ₹96,00,000 × 6% = ₹5,76,000
- Cash receipts: ₹24,00,000 × 8% = ₹1,92,000
- Presumptive income = ₹7,68,000
He would declare this as taxable PGBP without maintaining any books of account.
Section 44ADA — For Specified Professionals
For doctors, engineers, lawyers, CAs, architects, IT professionals with gross receipts ≤ ₹75,00,000:
- Presumed profit: 50% of gross receipts
- No books required
- Available to individuals and partnership firms only
Example: A CA in solo practice with ₹40,00,000 gross receipts can declare 50% = ₹20,00,000 as taxable income under 44ADA — no books, no audit.
Practice Exercises
Exercise 1: Sunrise Retail pays ₹12,000 in cash to a courier for delivery charges. Is this deductible?
Solution: A single cash payment exceeding ₹10,000 is disallowed under Section 40A(3). ₹12,000 exceeds the ₹10,000 limit.
Disallowance = ₹12,000 (100%). The entire amount is added back to net profit when computing PGBP.
If paid by NEFT or cheque, it would be fully deductible under Section 37.
Exercise 2: Sunrise Retail purchases a delivery van for ₹8,00,000 on 1 November 2025 (second half of FY). What is the IT depreciation for FY 2025-26?
Solution: Motor vehicle depreciation rate = 15%. November 2025 is in the second half of FY 2025-26 (October–March). Asset put to use for fewer than 180 days — 50% depreciation applies.
Normal depreciation = ₹8,00,000 × 15% = ₹1,20,000 Half-year restriction = ₹1,20,000 × 50% = ₹60,000
From FY 2026-27, full 15% on closing WDV (₹7,40,000) applies.
Exercise 3: A chartered accountant in solo practice has gross receipts of ₹60,00,000 in FY 2025-26. Can they use Section 44ADA? What is the taxable income?
Solution: A CA is a specified professional under Section 44ADA. Gross receipts ₹60,00,000 are below the ₹75,00,000 threshold. Yes, 44ADA applies.
Taxable income = 50% × ₹60,00,000 = ₹30,00,000
No books required, no audit required. No further deductions (depreciation, rent etc. are deemed included in the 50% profit calculation). The CA files ITR-4 (Sugam).
Key Terms
| Term | Definition |
|---|---|
| PGBP | Profits and Gains of Business or Profession |
| Section 37 | General business deduction — wholly and exclusively for business |
| Section 40(a) | TDS disallowance — 30% of payment if TDS not deducted or deposited |
| Section 40A(3) | Cash payment disallowance — 100% if single payment >₹10,000 in cash |
| Section 43B | Payments deductible only on actual payment basis — GST, PF, bonus |
| Block of assets | Pool of assets with the same depreciation rate — WDV is tracked at block level |
| WDV | Written Down Value — cost less accumulated depreciation |
| Half-year convention | 50% depreciation in year of addition if asset put to use for <180 days |
| Section 44AD | Presumptive taxation for small businesses — 8%/6% of turnover |
| Section 44ADA | Presumptive taxation for specified professionals — 50% of gross receipts |
Module Summary
- PGBP income = net P&L profit adjusted by adding disallowances and substituting IT depreciation for book depreciation.
- Section 37 allows all revenue expenditure wholly and exclusively for business; Sections 40(a), 40A(3), and 43B specify common disallowances.
- IT depreciation uses the WDV block method. Sunrise Retail's total IT depreciation = ₹1,71,500 for FY 2025-26.
- Sunrise Retail's taxable PGBP income = ₹30,68,500 after all adjustments.
- Section 44AD (businesses ≤ ₹3 crore, 6%/8% of turnover) and 44ADA (professionals ≤ ₹75L, 50% of receipts) apply only to individuals, HUF, and firms — not companies.
- Sunrise Retail cannot use 44AD because it is a company; Kiran's proprietorship Kiran Electronics could use it if turnover qualifies.
Quick Quiz
Q1: Sunrise Retail paid ₹1,50,000 professional fees without deducting TDS. How much is disallowed under Section 40(a)?
Answer: ₹45,000 — 30% disallowance.
Section 40(a)(ia) disallows 30% (not 100%) of the payment if TDS was not deducted. 30% × ₹1,50,000 = ₹45,000.
Options: A) ₹1,50,000 (100%) | B) ₹75,000 (50%) | C) ₹45,000 (30%) ✓ | D) Nil
Q2: A laptop costing ₹1,00,000 was purchased on 1 October 2025. IT depreciation rate is 40%. What is the depreciation for FY 2025-26?
Answer: ₹20,000.
October 2025 is the second half of FY 2025-26. Asset put to use for fewer than 180 days — 50% restriction applies. Normal depreciation = ₹40,000; half = ₹20,000.
Options: A) ₹40,000 | B) ₹20,000 ✓ | C) ₹10,000 | D) ₹25,000
Q3: Which expense requires actual payment before it can be claimed as a deduction under Section 43B?
Answer: C — Employer's contribution to Employees' Provident Fund.
PF contributions are covered by Section 43B(b) — they must be paid to the PF authority on or before the due date. Depreciation is a non-cash charge (not under 43B). Advertising is a regular Section 37 expense. 43B applies to GST, PF, bonus, and loan interest from FIs.
Options: A) Depreciation | B) Salary paid by bank transfer on 5 April | C) Employer PF contribution ✓ | D) Advertisement on credit
Q4: Why can't Sunrise Retail Pvt Ltd use Section 44AD presumptive taxation?
Answer: B — It is a company. Section 44AD is only available to resident individuals, HUFs, and partnership firms.
Companies are explicitly excluded from 44AD regardless of turnover. Even though Sunrise Retail's ₹2.80 crore turnover is below the ₹3 crore threshold, its entity type disqualifies it.
Options: A) Turnover exceeds ₹3 crore | B) It is a company — excluded ✓ | C) Electronics trading excluded | D) Employs more than 10 people
Next up: Module 5 — Chapter VI-A Deductions — The complete deduction menu under the old regime (80C, 80D, 80CCD, 80G, 80TTA, 80E, 80EEA), what actually survives in the new regime, and Kiran Sharma's full regime comparison with final tax figures.