Section 122
Section 122: general deductions to be made in computing total income
Section 122 opens Chapter VIII (which houses most of the Act's deductions, from Section 123 onward) with the ground rules that apply across the whole Chapter - how deductions are computed from gross total income, an overall cap, anti-double-claim rules, a timely-filing requirement for profit-linked deductions, and a market-value rule for goods or services transferred between an eligible undertaking and other businesses of the same assessee.
This explanation is AI-assisted and pending review by our CA/CS team. It is general information, not professional advice - always cross-check against the bare law text above or talk to our tax team for guidance specific to your situation.
How Chapter VIII deductions are computed
In computing an assessee's total income, the deductions specified in Chapter VIII are allowed from the assessee's gross total income, as per and subject to the provisions of the Chapter.
"Gross total income" for this purpose means the total income computed under the Act, before making any deduction under Chapter VIII.
Overall cap
The aggregate amount of deductions under Chapter VIII cannot, in any case, exceed the assessee's gross total income.
No double claim via an AOP/BOI member's share
Where a deduction under Section 133, 135, 137, 138, 141, 142 or 143 is allowed in computing the total income of an association of persons or a body of individuals, no deduction under that same section can be claimed again in relation to a member's share of that income when computing the member's own total income.
No deduction beyond the eligible undertaking's own profits
Irrespective of anything to the contrary in Part C of Chapter VIII, where profits and gains of an undertaking, unit, enterprise or eligible business are claimed and allowed as a deduction under those provisions for a tax year:
- Deduction in respect of, and to the extent of, those profits and gains cannot be allowed under any other provision of the Act for that tax year.
- The deduction can in no case exceed the profits and gains of that particular undertaking, unit, enterprise or eligible business.
Timely return required
A deduction under Part C of Chapter VIII is not allowed to an assessee who fails to furnish a return of income on or before the due date specified under Section 263(1), or who fails to make the deduction claim in a return furnished under Section 263(1).
Market-value rule for inter-unit transfers
Where goods or services held for the purposes of an eligible undertaking/unit/enterprise/business are transferred to another business of the same assessee (or vice versa), and the recorded consideration does not correspond to the market value of those goods or services on the transfer date, the profits and gains of the eligible undertaking are computed as if the transfer had been made at market value on that date.
"Market value" for goods or services sold/supplied means the open-market price (subject to statutory or regulatory restrictions); for goods or services acquired, it means the open-market acquisition cost; and where the transfer is a specified domestic transaction under Section 164, market value means the arm's length price as defined in Section 173(a).
Interaction with specified-business deduction under Section 46
Where a deduction under Part C of Chapter VIII is claimed and allowed for profits of a specified business referred to in Section 46(11)(d) for a tax year, no deduction can be allowed for that specified business under Section 46 for that or any other tax year.
How the deduction amount itself is computed
Where a Part C deduction is required to be made or allowed for income of a particular nature included in gross total income, the amount of income of that nature - as computed under the Act's provisions before any Chapter VIII deduction - alone is treated as the amount of that income derived or received by the assessee and included in gross total income, for purposes of computing the deduction.
Frequently asked questions
Can total deductions under Chapter VIII exceed gross total income?
No - Section 122(2) caps the aggregate of all Chapter VIII deductions at the assessee's gross total income.
Is filing the return on time necessary to claim Part C deductions?
Yes - a deduction under Part C of Chapter VIII is denied if the assessee fails to furnish the return by the due date under Section 263(1), or fails to claim the deduction in that return.
What happens if goods are transferred between an eligible undertaking and another business of the same assessee below market value?
The profits of the eligible undertaking are recomputed as if the transfer had happened at market value on the transfer date, to prevent profit-shifting that would inflate the deduction.
Related sections
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