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Case lawIncome-tax Act 2025Chapter VIII › Section 140
Chapter VIIIwas s.80

Section 140 of the Income-tax Act, 2025

Section 140 — Special provision in respect of specified business. Successor to s.80 of the 1961 Act.

Where this section sits

Section 140 is in Chapter VIII — Deductions to Be Made in Computing Total Income, which runs from section 122 to section 154.

← Section 139  ·  Section 141 →

What this section does

Sub-section (1) allows an eligible start-up whose gross total income includes profits from an eligible business a deduction of 100% of those profits for three consecutive tax years, and sub-section (2) lets the assessee pick which three, out of ten years from the year of incorporation. Sub-section (3) requires the start-up not to be formed by splitting up or reconstruction of an existing business and not by transfer of previously used machinery or plant, with sub-section (4) relaxing the first condition where a business destroyed by natural calamity, riot, fire, explosion or enemy action is revived within three years, sub-section (5) treating imported machinery never used in India and never depreciated here as not previously used, and sub-section (6) treating the second condition as met where transferred used plant is not more than 20% of the total value of plant in the business. Sub-section (7) computes the eligible business as the only source of income for quantifying the deduction in years after the initial year; sub-section (8) makes the deduction inadmissible unless the accounts are audited by an accountant before the specified date in section 63 and the report is filed by that date. Sub-sections (9) to (14) recompute inter-business transfers at market value or arm's length price, let the Assessing Officer adopt a reasonable basis in cases of exceptional difficulty, bar overlapping Part C claims and cap the deduction at the eligible business profits, and cut back more-than-ordinary profits arising from a close connection. Sub-section (15) lets the Central Government withdraw the benefit for a class of undertaking by notification, and sub-section (16) defines eligible business and eligible start-up — incorporated on or after 1 April 2016 but before 1 April 2030, turnover not exceeding three hundred crore rupees (raised from one hundred crore by Act No. 4 of 2026 with effect from 1 April 2026), and holding an Inter-Ministerial Board certificate.

Why it is there

It gives a qualifying start-up a full holiday on its business profits for three years of its choice in its first decade, while the formation conditions, the audit requirement and the transfer-pricing style adjustments keep the relief away from repackaged existing businesses and from profits shifted in from connected parties.

Who it applies to

The figures, and what each one turns on

Read the condition in the same row. A figure quoted without it is a wrong answer with a citation attached.
WhatFigureThe condition on itWhere
Rate of deduction100% of the profits and gains derived from the eligible businessFor three consecutive tax yearsSub-section (1)
Window from which the three years may be chosenTen yearsBeginning from the year in which the eligible start-up is incorporated; the choice is the assessee'sSub-section (2)
Time to revive a business destroyed by calamity and still be treated as not formed by reconstructionThree yearsFrom the end of the tax year in which the business was discontinued by reason of the damage or destructionSub-section (4)
Tolerance for previously used machinery or plant transferred to the new business20% of the total value of machinery or plant used in the businessAt or below this the condition in sub-section (3)(b) is deemed complied withSub-section (6)
Incorporation window for an eligible start-upOn or after 1st April 2016 but before 1st April 2030A condition of being an eligible start-upSub-section (16)(b)(i)
Turnover ceiling for an eligible start-upThree hundred crore rupeesTotal turnover of the business in the tax year relevant to the year of claim; substituted for 'one hundred crore rupees' by Act No. 4 of 2026 with effect from 1 April 2026Sub-section (16)(b)(ii)
Audit and report deadlineThe specified date referred to in section 63Accounts of the eligible business must be audited by an accountant before that date and the report furnished by that date, failing which the deduction is inadmissibleSub-section (8)

What this means in practice

Choose the three years deliberately — sub-section (2) lets you pick any three consecutive years within ten of incorporation, and sub-section (7) then computes the eligible business as if it were your only source of income for the years after the initial year. The audit is a condition of the deduction, not a formality: no audit and no report by the section 63 specified date means no deduction at all under sub-section (8). Watch the certificate and the turnover test in sub-section (16)(b): the Inter-Ministerial Board certificate is mandatory, and the turnover ceiling is three hundred crore rupees from 1 April 2026 following Act No. 4 of 2026, against one hundred crore before that. Transactions with the assessee's other businesses or with closely connected persons will be repriced under sub-sections (9) to (14) if they inflate the sheltered profits.

An example

Illustrative only, and invented for this page. The figures are chosen to show the rule biting, not taken from any real matter.

An eligible start-up incorporated in 2022, holding an Inter-Ministerial Board certificate, has turnover of Rs. 250 crore and Rs. 30 crore of profits from its eligible business. The turnover is within the ceiling as it now stands — three hundred crore rupees, substituted for one hundred crore by Act No. 4 of 2026 with effect from 1 April 2026 — so it may claim 100% of the Rs. 30 crore, for any three consecutive years it chooses out of ten from the year of incorporation. Two things can still take the claim away: second-hand plant of Rs. 5 crore transferred into a business whose total plant is Rs. 20 crore is 25%, breaching the 20% tolerance in sub-section (6) and so the condition in sub-section (3)(b); and if the accounts are not audited before the specified date in section 63 with the report furnished by that date, sub-section (8) makes the deduction inadmissible however good the claim otherwise is.

Where you meet this section

In the return of a start-up claiming the deduction, supported by the audit report in the prescribed form required by sub-section (8) and filed by the section 63 specified date, and by the certificate of eligible business from the Inter-Ministerial Board of Certification. Then in the assessment, where the Assessing Officer may recompute transfers between the assessee's businesses at market value or arm's length price and cut back more-than-ordinary profits arising from a close connection.

The words themselves

there shall, as per and subject to the provisions of this section, be allowed, in computing the total income of the assessee, a deduction of an amount equal to 100% of the profits and gains derived from such business for three consecutive tax years
s.140(1), Income-tax Act, 2025.

What people get wrong

What this replaced

The correspondence is the Income Tax Department’s own, from its comparison utility for the 1961 and 2025 Acts. A renumbering is the easy half; whether the words changed is the half that decides cases.

See the full 1961 to 2025 concordance.

Rules that serve this section

Rules of the Income-tax Rules, 2026 that work section 140. Where the rule’s own heading names the section we say so; the rest are marked on reading the rule, which is our derivation and not the department’s. A rule that serves the section silently and that we have missed will not appear here.

All of them are in the Rules 2026 index.

Circulars of the Board on this section

A circular binds the department, not you and not a court. Every one below was written under the 1961 Act; it reaches this section because the department’s own concordance carries the provision it names to this one.

See every circular and notification on this section, or the circulars index.

Notifications that reach this section

A notification is made under a power the Act gives and, within that power, is law. These too were made under the 1961 Act and are placed here by the department’s concordance.

See every circular and notification on this section, or the notifications index.

Case law carried across

Read this before you rely on it. Every decision below was decided under the Income-tax Act, 1961. It appears here because it is tagged to a 1961 provision that the department’s own mapping carries to section 140. That is an inference we have drawn, not a holding on the new section: where the words changed in the move, the reasoning may not survive. Treat this as the place to start looking, not as authority on the 2025 Act.

Explainers

Read with

What this page does not tell you. It does not reproduce the section. Everything above was written from the section’s own text as the Income Tax Department publishes it — the text is here, and nothing here is advice on your facts. Where a figure matters, read the sub-section it comes from.