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Case lawCBDT Circulars & Instructions › MSME Office Memorandum 1/4(1)/2021
CBDT Circulars & InstructionsCuts both waysValidity unconfirmeds.43B(h)MSMED Act 2006 s.2(e)MSMED Act 2006 s.15

MSME Office Memorandum 1/4(1)/2021

My supplier is a trader with Udyam registration. Does the 43B(h) disallowance apply to him?

My supplier is a trader with Udyam registration. Does the 43B(h) disallowance apply to him?

No. The Ministry of MSME's memorandum confines the benefit of Udyam registration for wholesale and retail traders to Priority Sector Lending; the delayed-payment provisions of the MSMED Act, including s.15, are excluded. Since clause (h) works by reference to the s.15 time limit, purchases from traders fall outside it.

Decided by the CBDT Circulars & Instructions (Ministry of Micro, Small and Medium Enterprises, Policy Division, Government of India) on 2021-09-01, reported as OM No. 1/4(1)/2021-P&G/Policy; OM No. 5/2(2)/2021-E/P&G/Policy. It bears on section 43B(h), section MSMED Act 2006 s.2(e), section MSMED Act 2006 s.15 of the Income Tax Act 1961, in Deductions & Disallowances matters.

Read this before you cite it. This is an administrative limitation being read across into a tax provision. No court has ruled on it and the memorandum said to state it could not be obtained. Do not present it to a client as a settled answer on section 43B(h).
Validity check could not be completed. The proposition this entry carries has not been tested. The Office Memorandum of 1 September 2021, No. 1/4(1)/2021-P&G/Policy, could not be found as a document in a subscription research database - a search on its file number returned only two commentary articles citing it. What was found is the earlier decision it is said to restate: RBI Circular No. FIDD.MSME & NFS.BC.No.13/06.02.31/2021-22 dated 7 July 2021 records that the Ministry decided by Office Memorandum No. 5/2(2)/2021-E/P&G/Policy dated 2 July 2021 to include retail and wholesale trade as MSMEs for the limited purpose of Priority Sector Lending, with Udyam registration under NIC codes 45, 46 and 47. No CBDT circular or notification adopting that limitation for section 43B(h) was traced, and no judicial decision on the point was found. Section 43B(h) itself is in force and is carried into the Income-tax Act 2025 as section 37(2)(g), with the carve-out in section 37(3) preserved for tax years beginning on or after 1 April 2026. The classification criteria for micro, small and medium enterprises are reported to have been revised in March 2025; that revision was not located in this pass and nothing read shows it altering the traders' position.

Why it matters

Traders were brought into Udyam registration in July 2021, and a Udyam number on a trader's invoice is now the commonest reason a clause (h) add-back gets made when it should not be. The memorandum is the answer to that: registration for these NIC codes buys lending benefits only. It cuts both ways — a trader-supplier cannot use the delayed-payment machinery against you, and you cannot be disallowed for paying him late.

Binding on the department, not on the assessee or the courts. An assessee may rely on a circular that is beneficial to them.

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