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Specialised Tax Services

Business Incentives Review

Practice01/06

Central Tax Incentives.

Note01
Transition-only brought-forward MAT credit utilisation under Section 115JAA [ITA 2025: s. 206(3)-(4)], Section 35 [ITA 2025: s. 45] R&D deductions, and Section 115BAA [ITA 2025: s. 200] concessional rate.
Index06 Practices
01Central Tax Incentives
02PLI Scheme Assessment
03Location-Based Benefits
04Startup Tax Benefits
05Export Incentives
06State Industrial Incentives

Scope of Our Review

Tax benefits span income tax, GST, customs, and state industrial policies. Our review maps your operations against applicable incentive frameworks.

Central Tax Incentives

Reviewing eligibility for provisions under the Income Tax Act, including transition-only provisions for brought-forward MAT credit under Section 115JAA [ITA 2025: s. 206(3)-(4)], R&D deductions under Section 35 [ITA 2025: s. 45], and concessional tax rates under Sections 115BAA [ITA 2025: s. 200] and 115BAB [ITA 2025: s. 201].

PLI Scheme Assessment

Evaluating qualification for Production Linked Incentive schemes across 14 notified sectors including electronics, pharmaceuticals, textiles, and auto components.

Location-Based Benefits

Analysing eligibility for SEZ benefits under Section 10AA [ITA 2025: s. 144], IFSC unit incentives, and state industrial policy subsidies for backward-area investments.

Startup Tax Benefits

Assessing eligibility for the three-year tax holiday available to qualifying startups incorporated before April 2030 under Section 80-IAC [ITA 2025: s. 140].

Export Incentives

Reviewing qualification for export promotion schemes, customs duty concessions, RoDTEP benefits, and Advance Authorisation under foreign trade policy.

State Industrial Incentives

Mapping your investments against state-specific capital subsidies, power tariff rebates, stamp duty exemptions, and employment-linked benefits.

Why Conduct This Review

Incentive frameworks are spread across multiple statutes and jurisdictions. A structured review can surface benefits that may otherwise remain unclaimed.

  • Identify applicable benefits across central tax laws and state policies
  • Assess whether current claims meet eligibility and documentation requirements
  • Understand the financial impact of each potential benefit
  • Prepare substantiation that can withstand assessment and scrutiny
  • Align incentive claims with compliance obligations under the new tax framework

Our Review Process

Step 1

Incentive Mapping

We map your business activities—sector, location, investments, exports, R&D—against the current landscape of central and state incentives to identify potentially applicable benefits.

Step 2

Eligibility Assessment

Each identified incentive is evaluated against its specific eligibility conditions, including investment thresholds, sectoral requirements, timelines, and documentation standards.

Step 3

Claim Structuring

We advise on structuring claims correctly—timing of applications, required certifications, procedural compliance, and interaction with the new Income Tax Act, 2025 provisions.

Step 4

Filing Support

We assist in compiling supporting documentation and ensure claims are accurately reflected in tax returns, PLI applications, or state incentive submissions.

Common Questions

  1. What does a business incentives review involve?

    A business incentives review maps your operations against the tax benefits available across central and state laws, then checks which ones you can claim. We look at your sector, location, investment, exports, and research activity, compare them against the eligibility conditions of each incentive, and identify benefits that may be unclaimed. The review also tests whether existing claims meet documentation standards. The output is a list of applicable incentives with their conditions, financial effect, and the steps to claim them.

  2. Which categories of tax incentive could apply to a business in India?

    Tax incentives in India sit across several frameworks. Central income tax law offers concessional company rates, research deductions, and profit-linked holidays. The Production Linked Incentive (PLI) scheme rewards manufacturing in notified sectors. Location-based benefits apply to Special Economic Zones and IFSC units. Export schemes such as RoDTEP refund embedded duties. State industrial policies add capital subsidies and other concessions. Which of these apply depends on what your business does and where, so we assess your profile against each framework rather than assuming a single benefit fits.

  3. What is the concessional corporate tax rate under Section 115BAA [ITA 2025: s. 200], and is it still available?

    Section 115BAA [ITA 2025: s. 200] lets a domestic company pay tax at 22% plus a 10% surcharge and 4% cess, an effective rate of about 25.17%. The company must give up the deductions and incentives specified in the provision, and the choice is irreversible once made. A company validly opting for this regime is outside Minimum Alternate Tax under Section 115JB [ITA 2025: s. 206]. It remains available to both new and existing domestic companies. We model the trade-off before a company opts in, since the deductions surrendered can outweigh the lower rate.

  4. Can new manufacturing companies still opt for the 15% rate under Section 115BAB [ITA 2025: s. 201]?

    The 15% concessional rate for new manufacturing companies under Section 115BAB [ITA 2025: s. 201] is closed to new entrants. The law required the company to be set up on or after 1 October 2019 and to commence manufacturing on or before 31 March 2024. A company that already opted in continues at the rate, but a company incorporated now cannot newly elect it unless the window is reopened by future legislation. We confirm current eligibility before treating this rate as available, and consider Section 115BAA [ITA 2025: s. 200] as the alternative concessional route.

  5. What deduction is available for research and development expenditure?

    Expenditure on in-house research and development, and contributions to approved research institutions, can qualify under Section 35 [ITA 2025: s. 45]. The weighted deductions that once applied have largely been rationalised to the actual amount spent. A company opting for Section 115BAA [ITA 2025: s. 200] must forgo the specified Section 35 [ITA 2025: s. 45] deductions excluded by that regime, including Section 35(2AB) [ITA 2025: s. 45(2)], so the choice must be assessed together rather than separately. We review the expenditure, approval and exact deduction clause before a claim is made.

  6. How does Minimum Alternate Tax interact with incentive claims?

    Minimum Alternate Tax under Section 115JB [ITA 2025: s. 206] sets a floor of 15% of book profit for a company and year governed by the 1961 Act. From tax year 2026-27, the corresponding rate is 14% for a company other than a qualifying 9% IFSC company. It does not apply where the company has validly opted for Section 115BAA [ITA 2025: s. 200]. A profit-linked deduction such as Section 80-IAC [ITA 2025: s. 140] may therefore reduce regular tax while the applicable MAT remains payable. Credit under Section 115JAA [ITA 2025: s. 206(3)-(4)] could be carried forward for up to 15 years; the transition-only provisions corresponding to Section 115JAA [ITA 2025: s. 206(3)-(4)] preserve specified credit brought forward as at 31 March 2026 subject to their transition conditions—including the 25% annual set-off cap for a domestic company within their scope—while the Finance Act 2026 omitted the former general new-company MAT-credit clauses. We confirm the company, tax year, regime and available brought-forward credit before including MAT in the incentive cash-flow model.

  7. What tax holiday is available to startups under Section 80-IAC [ITA 2025: s. 140]?

    Section 80-IAC [ITA 2025: s. 140] offers an eligible startup a deduction of 100% of profits for any three consecutive years within its first ten years. To qualify, the entity must be a private limited company or LLP incorporated on or after 1 April 2016 and before 1 April 2030, recognised by the DPIIT, and certified by the Inter-Ministerial Board. Its eligible business must involve innovation, development or improvement of products, processes or services, or a scalable business model with high potential for employment generation or wealth creation, and it must not be formed by splitting up or reconstructing an existing business. Under Section 80-IAC [ITA 2025: s. 140], turnover must not exceed Rs 100 crore in the relevant year; under Section 80-IAC [ITA 2025: s. 140] from 1 April 2026, the corresponding ceiling is Rs 300 crore. We help test eligibility under the regime governing the claim year and choose which three years to claim.

  8. How does a startup claim the Section 80-IAC [ITA 2025: s. 140] tax holiday?

    Claiming the holiday runs in two stages. First, the startup obtains DPIIT recognition through the National Single Window System, then applies to the Inter-Ministerial Board for the tax exemption certificate, submitting audited financials, shareholding details, and a description of its product or process. Once the Board certifies the startup, the deduction is claimed in the income tax return for the chosen three consecutive years. Because the three years can be selected within the first ten, we advise modelling profits first so the holiday lands in the higher-profit years.

  9. What is the Production Linked Incentive (PLI) scheme and how does it work?

    The Production Linked Incentive (PLI) scheme pays eligible manufacturers an incentive on the incremental sales of goods made in India over a base year. Rates vary by sector, broadly in the range of 4% to 6% of incremental sales, against committed investment. The scheme covers 14 notified sectors, including electronics and mobiles, pharmaceuticals, telecom, automobiles and auto components, textiles, specialty steel, food products, and solar modules. Each sector has its own guidelines, base year, and targets. We check the sector notification that applies to your products before advising on a claim.

  10. Who is eligible for a PLI scheme?

    Eligibility depends on the sector-specific notification rather than a single rule. Most schemes set a minimum investment commitment and incremental sales or production targets that a company must meet to draw the incentive, and applications are made to the administering ministry within a defined window. Both Indian and foreign-owned manufacturers producing in India can apply where their products fall within the notified scope. We assess your planned investment and output against the relevant sector guidelines before an application is prepared.

  11. What tax benefits apply to units in a Special Economic Zone or IFSC?

    A unit in a Special Economic Zone (SEZ) may claim a deduction on export profits under Section 10AA [ITA 2025: s. 144], but this benefit is sunset for new units: only units that began manufacturing, producing articles or things, or providing services before 1 April 2021 can claim it, subject to the provision's taper over fifteen years and other conditions. Units in an International Financial Services Centre (IFSC), such as GIFT City, have a separate set of concessions for eligible activities, including the unit deduction under Section 80LA [ITA 2025: s. 147]. Because the SEZ income tax holiday has closed for new units, we assess whether IFSC benefits, customs advantages, or state incentives are the more relevant route.

  12. What export incentives can exporters claim?

    Exporters can access several schemes outside income tax. RoDTEP remits embedded central, state, and local duties that other schemes do not refund. RoSCTL covers garments and made-ups. The Export Promotion Capital Goods (EPCG) scheme allows duty-free import of capital goods against an export obligation. Advance Authorisation allows duty-free import of inputs used in export production. These operate under the Foreign Trade Policy and customs law rather than the Income Tax Act. We map your export profile against each to identify which deliver value for your goods.

  13. Is the RoDTEP scheme still active, and how is the benefit claimed?

    RoDTEP is active, and its benefits were restored for Advance Authorisation, SEZ, and Export Oriented Unit exports during 2025. The benefit is a percentage of the shipment's Free on Board value, currently notified between about 0.3% and 4.3% depending on the product. To claim it, the exporter declares the intent on the shipping bill, the carrier files the export manifest, and customs processes a credit that becomes a transferable electronic scrip in the ICEGATE ledger. The scrips can pay basic customs duty or be sold to another importer. We help set up the claim and track scrip use.

  14. What state-level industrial incentives might a business qualify for?

    State industrial policies offer benefits that sit alongside central incentives. Depending on the state and the location of the investment, these can include capital investment subsidy, interest subsidy, power tariff rebate, stamp duty and registration fee exemption, reimbursement of state GST, and employment-linked grants. Backward or priority areas usually carry higher benefits. Each state runs its own policy, eligibility criteria, and nodal agency, and most require an eligibility certificate before benefits are released. We map your investment against the policy of the relevant state.

  15. How has the Income Tax Act 2025 changed the section references for these incentives?

    The Income Tax Act 2025, in force from 1 April 2026 subject to repeal and savings, renumbered the provisions startups rely on. The relevant provisions are the concessional company rate under Section 115BAA [ITA 2025: s. 200], the new-manufacturing rate under Section 115BAB [ITA 2025: s. 201], the startup deduction under Section 80-IAC [ITA 2025: s. 140], the SEZ unit deduction under Section 10AA [ITA 2025: s. 144], the IFSC unit deduction under Section 80LA [ITA 2025: s. 147], the research deduction under Section 35 [ITA 2025: s. 45], and Minimum Alternate Tax under Section 115JB [ITA 2025: s. 206]. The applicable provision follows the income and claim period together with the repeal-and-savings rules. We cite the provision that applies to the year in question and confirm the current clause when a claim is filed.

  16. What documentation supports an incentive claim if it is reviewed or audited?

    Most incentives turn on documentation that can withstand later review. Depending on the benefit, this can include the DPIIT recognition and Inter-Ministerial Board certificate for a startup, the SEZ letter of approval, the state eligibility certificate, the PLI application and audited sales data, shipping bills and scrip records for export schemes, and a chartered accountant's certification in the prescribed form for income tax deductions. We help assemble and maintain this record so a claim is substantiated if it is questioned during assessment or scrutiny.