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Case lawCBDT Circulars & Instructions › Statutory position — s.80-IAC: the start-up deduction, the incorporation cut-off, and the s.80AC bar on a late return
CBDT Circulars & InstructionsCuts both wayss.80-IACs.80ACs.80A(5)s.80-IAs.139(1)s.33B

Statutory position — s.80-IAC: the start-up deduction, the incorporation cut-off, and the s.80AC bar on a late return

Until when must a start-up be incorporated to claim s.80-IAC, and what happens to the claim if the return is filed late?

Until when must a start-up be incorporated to claim s.80-IAC, and what happens to the claim if the return is filed late?

As the section currently reads, an eligible start-up must be incorporated on or after 1 April 2016 but before 1 April 2030 — the date was substituted for 2025 by Act No. 7 of 2025 with effect from 1 April 2025, which is the extension relied on here. The deduction is one hundred per cent of the profits of the eligible business for three consecutive assessment years, claimable at the assessee's option out of ten years beginning with the year of incorporation, and it is lost entirely if the return is filed after the due date under s.139(1), because s.80AC bars every deduction under the Chapter VI-A heading 'C.—Deductions in respect of certain incomes' in that event.

Decided by the CBDT Circulars & Instructions (Not applicable — statutory text) on 2025-04-01, reported as Section 80-IAC, Income-tax Act 1961, incorporation cut-off substituted by Act No. 7 of 2025 with effect from 1 April 2025; section 80AC as substituted by the Finance Act 2018 with effect from 1 April 2018. It bears on section 80-IAC, section 80AC, section 80A(5), section 80-IA, section 139(1), section 33B of the Income Tax Act 1961, in Deductions & Disallowances and Assessment & Scrutiny matters.

Still good law. The text of s.80-IAC is taken from the department's current section page, Year stamp 2026, which names Act No. 7 of 2025 as the enactment that substituted the 1 April 2030 cut-off with effect from 1 April 2025. The text of s.80AC is taken from a Karnataka High Court judgment of 13 January 2026 reproducing it, not from a departmental page, because the department's /w/section-80ac page is an archived 2009 version carrying the pre-2018 text. I did not search for judicial decisions construing s.80-IAC itself; the only decision retrieved that touches it, Herald Global Ventures Private Limited v CCIT-1 (Gujarat High Court, 16 March 2026), concerns the consequence of an Inter-Ministerial Board refusal and not the construction of the section.

Why it matters

The s.80AC bar is absolute and is the commonest way this deduction is lost — it operates on the date of the return, not on the merits, and s.80-IAC sits squarely under heading C of Chapter VI-A. Section 80A(5) adds a second, independent bar: no deduction under that heading is allowed at all unless the claim is made in the return of income. Beyond timing, three conditions do the work. The start-up must hold a certificate of eligible business from the Inter-Ministerial Board of Certification notified in the Official Gazette; without it there is no deduction however plainly the business qualifies, as Herald Global Ventures Private Limited v CCIT shows, where the Board refused the certificate because a director held majority shareholding in the group. Total turnover in the relevant previous year must not exceed one hundred crore rupees. And the entity must be a company or a limited liability partnership — a firm or a proprietorship is outside the definition. The three-out-of-ten structure is a planning choice and a trap: choose the wrong three years and the benefit is spent against low profits, but the Gujarat High Court has held that the availability of later years is not an answer to hardship caused now.

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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