Statutory BulletinROC Compliance & Share Allotment
Corporate Tax & 80PA

Section 80PA FPC Tax Exemption: What Changed in 2025–26

Section 80PA's 100% profit deduction expired after AY 2024-25. Learn how FPCs should use Section 115BAA, Section 37 patronage bonus, and Section 10(1) agricultural income exemptions instead.

CA Andre, Vihara FoundationPublished 1 September 2026Updated 25 September 20267 min read

If your Farmer Producer Company filed taxes relying on Section 80PA for a 100% profit deduction, here is the critical update: the provision expired after Assessment Year 2024-25 (Financial Year 2023-24). Parliament did not renew it in Finance Act 2024.

What Was Section 80PA?

Section 80PA allowed Producer Companies with annual turnover below ₹100 Crore to claim a 100% deduction on profits from eligible activities — procurement, marketing, and supply of agricultural inputs to farmer members.

It was introduced in Finance Act 2018 as a sunset provision with a five-year window. That window closed with AY 2024-25.

What Should FPCs Use Instead in 2025-26?

Three tax levers remain active and powerful:

1. Section 115BAA — 22% Flat Corporate Tax Rate

FPCs that filed Form 10-IC before the AY deadline are locked into the 22% concessional rate (25.17% all-inclusive). This is permanently lower than the 30% standard rate. If your FPC has not yet elected this option, consult a CA immediately — the election cannot be retroactively applied.

2. Section 37 — Patronage Bonus as Business Deduction

Surplus distributed to farmer members as patronage bonus or price-difference payment is deductible as an ordinary business expense before calculating net taxable profit. This is the most powerful tax lever for FPCs with high member volumes. Maintain separate farmer-wise patronage ledgers to substantiate the deduction.

3. Section 10(1) — Agricultural Income

Income derived purely from agriculture (crop cultivation, harvesting, storage by the FPC on behalf of members) remains fully exempt. Critically: processing income, trading margins, and commission from non-member transactions are not agricultural income.

Protecting Prior-Year 80PA Claims

CPC is actively issuing Section 143(1) intimations and Section 143(3) scrutiny notices for FPCs that claimed 80PA in AY 2019–2024. The most common disallowance reasons:

  • Mixing of member-sourced and third-party procurement in a single invoice stream
  • Insufficient member-produce linkage documentation (7/12 extracts, weighment slips)
  • Failure to maintain separate books for eligible vs non-eligible activities

Vihara Foundation prepares pre-assessment defense files including activity segregation statements and statutory audit certification to contest these notices.

Action Items for FPC CEOs and Accountants

  1. Confirm whether Form 10-IC was filed to elect Section 115BAA
  2. Set up a patronage ledger that ties each bonus payment to a specific member's produce supply record
  3. Separate agricultural income from processing/trading income in your accounting software from April 1 each year
  4. If you received a Section 143(1) notice disallowing 80PA, contact a qualified CA within 30 days of the intimation date

Need help? Vihara Foundation's 12-Month Governance Academy covers Section 115BAA strategy, 80PA defence documentation, and live monthly masterclasses on FPC tax compliance.

Frequently Asked Questions

Quick answers from our compliance team

Is Section 80PA still available for FPCs in 2025-26?

No. Section 80PA had a statutory sunset clause and was available only up to AY 2024-25 (FY 2023-24). Parliament did not extend it in Finance Act 2024. FPCs should now use Section 115BAA (22% flat corporate rate), Section 37 patronage bonus deduction, and Section 10(1) agricultural income exemption.

What is the corporate tax rate for Farmer Producer Companies in 2026?

FPCs that filed Form 10-IC before the deadline can elect Section 115BAA at 22% (25.17% all-inclusive with surcharge and cess). FPCs that missed the election default to the normal 30% slab.

Can an FPC still get scrutiny notices for 80PA claims from previous years?

Yes. CPC Section 143(1) and Section 143(3) scrutiny notices for AY 2019–2024 are active. Vihara Foundation provides pre-assessment defense documentation including activity segregation statements and member-produce linkage proofs.

Need hands-on compliance support?

Vihara Foundation runs live sessions on FPC compliance. Each session is registered for separately, with or without its recording and kit.