Section 47 prescribes 150% / 100% deduction (post FA 2016 sunset to 100%) for expenditure on agricultural-extension projects (1961 s. 35 CCC) and skill-development projects (1961 s. 35 CCD). The deductions are aimed at incentivising rural…
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ITA 2025 · Section 47
Section 47 — EXPENDITURE ON AGRICULTURAL EXTENSION PROJECT AND SKILL DEVELOPMENT PROJECT
Section 47 prescribes 150% / 100% deduction (post FA 2016 sunset to 100%) for expenditure on agricultural-extension projects (1961 s. 35CCC) and skill-development projects (1961 s. 35CCD). The deductions are aimed at incentivising rural / vocational-training investment. Cost of land / building is excluded.
STATUTORY ARCHITECTURE
Section 47 is a sectoral-incentive deduction. Agricultural-extension projects must be CBDT-notified per Income-tax Rules, 2026 r. 6AAD-equivalent; skill-development projects must be operated by approved institutions and CBDT-notified per Rule 6AAH-equivalent. FA 2016 sunset reduced the rate from 150% to 100% for both categories from AY 2017-18 onwards.
PLANNING NOTES
(i) For corporate CSR (s. 135 of Companies Act, 2013) directed at agri-extension or skill-development, evaluate dual benefit — CSR compliance + s. 47 deduction. CSR expenditure as such is NOT s. 32 deductible (Explanation 2 to s. 32), but where the expenditure ALSO qualifies as s. 47 agri/skill expenditure, the s. 47 route opens. (ii) Maintain CBDT-notification reference + audit certification for the project.
CROSS-REFERENCES