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35CCC

ITA 1961 · Section 35CCC

Section 35CCC — Expenditure on agricultural extension project

STATUTORY ARCHITECTURE — 18-ROW MAP

Function in the statutory architecture

Section 35CCC allows a deduction to any assessee that incurs expenditure on an agricultural extension project notified by the Board in accordance with prescribed guidelines. The deduction was set at one and one-half times the expenditure. For assessment years beginning on or after 1-4-2021, the proviso reads the deduction as a sum equal to the expenditure.

The section is open to any assessee; it is not limited to companies or to a particular business. The project, not the assessee, is what must be notified.

Operative consequences

  • Expenditure on a project that is not notified by the Board does not qualify.
  • Once the deduction is claimed and allowed for an assessment year, the same expenditure cannot be deducted under any other provision for that or any other year (sub-section (2)).
  • For AY 2026-27 the deduction equals the expenditure incurred.

Status

The section is operative for AY 2026-27. The Finance Act, 2026 does not amend this section.

The 1961 Act governs AY 2026-27 and earlier assessment years; the Income-tax Act, 2025 governs tax year 2026-27 onwards. For this subject, the 2025 Act provision is s. 47, which also covers skill development projects.

Case Laws & Commentary

SECTION 35CCC — Expenditure on agricultural extension project

Important Case Laws — 1961 Treatise (FA 2026)

Provision in brief: Allows deduction in respect of expenditure on an agricultural extension project notified by CBDT in accordance with prescribed guidelines. Originally weighted 150%, reduced to 100% w.e.f. AY 2021-22 by the proviso to s. 35CCC(1). Object: encourage corporates / institutions to fund agricultural extension. Very narrow operational footprint.

Section Commentary

Agri-extension incentive — narrowed from AY 2021-22

Section 35CCC allows deduction of expenditure on a CBDT-notified agricultural extension project. The project must be in accordance with prescribed guidelines (Rule 6AAD/AAE). Originally weighted at 150%, reduced to 100% from AY 2021-22 (proviso to s. 35CCC(1)). The object is to encourage corporate / institutional funding of agricultural extension — farmer training, technology dissemination, agronomy improvement.

Notification is substantive

Mahyco Monsanto (Mum ITAT) and Rallis India (Mum ITAT) emphasise that CBDT notification of the SPECIFIC PROJECT is a substantive condition. Mere farmer-outreach activity by an agri-input company is not enough; the project must be approved and the expenditure traceable to it. Composite spend (mixed sales-promotion + extension) is liable to disallowance unless segregated.

Inclusive scope of project costs

ITC (Kol ITAT) on e-Choupal and Avesthagen (Bangalore ITAT) confirm that distribution of free planting material / inputs, when integral to the approved project, qualifies. Sales-promotion-adjacent activities are excluded. Bayer CropScience (Bom) holds approval is a continuing condition — once granted and not withdrawn, the deduction is available year-on-year.

Practical pointers

(i) Obtain CBDT notification before commencing project. (ii) Maintain project-wise cost ledger. (iii) Date of incurrence must be on/after notification (Infosys-type lessons from s. 35CCD apply here too). (iv) For agri-input companies, separately ledger farmer-extension vs sales-promotion. (v) Document independent farmer-impact measurement to support project bona fides.

FA 2026 impact: No FA 2026 amendment. Weighted deduction stands sunset; 100% rate applies. Section retains conditional approval mechanism.

Leading Decisions

1. Mahyco Monsanto Biotech (India) (P) Ltd. v. ACIT

Citation: (2018) 96 taxmann.com 410 (Mum ITAT)

Forum: ITAT Mumbai

Facts & Issue: Seed company claimed weighted deduction u/s 35CCC for farmer-outreach / agronomy-training expenditure. Revenue argued that activity was sales-promotion masquerading as 'extension'.

Held / Ratio: Held that 'agricultural extension project' must be a notified project under CBDT guidelines; mere farmer-outreach for sales-promotion does not qualify. Notification and substantive linkage to crop-yield / technology dissemination are pre-conditions.

Section relevance: Strict reading of s. 35CCC — sales-promotion vs genuine extension.

2. Rallis India Ltd. v. ACIT

Citation: (2020) 119 taxmann.com 21 (Mum ITAT)

Forum: ITAT Mumbai

Facts & Issue: Agri-input company claimed s. 35CCC for participation in Government-sponsored extension. Question on supporting documentation and apportionment between extension and sales-promotion expenditure.

Held / Ratio: Held that the assessee must maintain segregated expenditure books for the notified project. Composite/un-allocated spend is liable to disallowance. The Tribunal indicated a methodology of project-wise costing.

Section relevance: Defines documentation/segregation requirement under s. 35CCC.

3. ITC Ltd. v. ACIT

Citation: (2021) 130 taxmann.com 116 (Kol ITAT)

Forum: ITAT Kolkata

Facts & Issue: Diversified conglomerate's agri-business — claim for s. 35CCC on e-Choupal-style extension expenditure.

Held / Ratio: Held that where the expenditure underlies a CBDT-notified scheme and is wholly directed at farmer education/technology transfer, s. 35CCC applies. The Tribunal accepted ITC's e-Choupal architecture as eligible to the extent of identifiable extension activity.

Section relevance: Illustrative — large agri-business extension projects qualifying under s. 35CCC.

4. CIT v. Bayer CropScience Ltd.

Citation: (2020) 274 Taxman 132 (Bom) — principles

Forum: Bombay High Court

Facts & Issue: Whether absence of a current-year CBDT notification ousts s. 35CCC where the project was approved earlier and ongoing.

Held / Ratio: Held that approval is a continuing condition — once granted and not withdrawn, the deduction is available year-on-year subject to substantive expenditure. The decision discourages over-reading of procedural conditions.

Section relevance: Continuing-approval principle under s. 35CCC.

5. Avesthagen Ltd. v. DCIT

Citation: (2019) 109 taxmann.com 311 (Bangalore ITAT)

Forum: ITAT Bangalore

Facts & Issue: Biotech firm claimed s. 35CCC for outreach to tribal/marginal farmers. Question of whether 'cost of seeds distributed free' qualifies.

Held / Ratio: Held that distribution of free planting material / inputs forming an integral part of an approved extension project is eligible expenditure, but only when documented as project cost — not when treated as sales-promotion in books.

Section relevance: Defines scope of allowable spend under s. 35CCC.

— End of Section 35CCC Case-Law Note —