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Income from Business vs Income from Profession – Definitions

Are you a businessman or professional? Tax treatment differs! A doctor earning ₹10 lakh is different from shopkeeper earning ₹10 lakh (for tax purposes). Let's understand why.


Section 28: Profits & Gains of Business or Profession (PGBP)

Third income head: Business or Profession

Two sub-categories:

  1. Business
  2. Profession

Same sections apply (28-44) but some differences in treatment


What is Business?

Definition: Any trade, commerce, or manufacture carried on with profit motive

Section 2(13): "Business includes any trade, commerce or manufacture or any adventure or concern in the nature of trade, commerce or manufacture"

Key characteristics:

  • Profit motive: Primary purpose is earning
  • Regular activity: Continuous/repeated transactions
  • Organization: Some level of structure
  • Risk: Uncertainty in returns

Examples:

  • Retail shop (grocery, clothes)
  • Manufacturing (factory, production)
  • Wholesale trading
  • E-commerce (Amazon seller)
  • Restaurant
  • Construction
  • Import/Export

What is Profession?

Definition: Activity requiring specialized knowledge and skill, involving personal efforts

Section 2(36): "Profession includes vocation"

Characteristics:

  • Qualification required: Degree, certification
  • Expertise: Specialized knowledge
  • Personal service: Cannot be easily delegated
  • Professional ethics: Code of conduct
  • Professional body: CA, Doctor, Lawyer associations

Examples:

  • Medical: Doctor, Dentist, Surgeon
  • Legal: Advocate, Lawyer
  • Accounting: Chartered Accountant, Cost Accountant
  • Architecture: Architect
  • Engineering: Consulting Engineer
  • Technical: Film Artist, Author, Sportsperson

Detailed Comparison

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Key Differences

AspectBusinessProfession
NatureTrade, commerce, manufactureIntellectual/skilled service
QualificationNot mandatoryRequired (MBBS, CA, LLB)
TransferCan be sold/transferredCannot transfer (personal)
IncomeProfit from tradingProfessional fees
Presumptive taxSection 44AD (8% presumption)Section 44ADA (50% presumption)
Audit limit₹1 crore turnover₹50 lakh gross receipts
BooksCan maintain simplifiedMust maintain proper books

Practical Examples

Example 1: Clear Business

Rajesh runs a grocery shop:

  • Buys from wholesaler
  • Sells to customers
  • Profit motive: Buy at ₹90, sell at ₹100
  • Business income

Example 2: Clear Profession

Dr. Sharma:

  • MBBS degree
  • Treats patients
  • Charges consultation fees
  • Professional income

Example 3: Business or Profession?

Software Developer:

  • As employee: Salary (not business/profession)
  • Freelancer (B.Tech degree): Profession (technical consultant)
  • Runs software company: Business

IT Consultant (no formal degree, self-taught):

  • Provides services
  • Borderline: Could be business (no mandatory qualification for IT consulting)

Presumptive Taxation Difference

Section 44AD - Business (Specified)

For small businesses (turnover < ₹2 crore):

  • Presumed profit: 8% of turnover (digital), 6% (cash)
  • No need to maintain books
  • Simplified tax filing

Example:

Shopkeeper turnover: ₹50 lakh

  • Presumed income: ₹50L × 8% = ₹4 lakh
  • Tax on ₹4L (no actual expense calculation needed!)

Section 44ADA - Profession (Specified)

For professionals (gross receipts < ₹50 lakh):

  • Presumed income: 50% of gross receipts
  • No books required

Example:

Doctor fees: ₹30 lakh

  • Presumed income: ₹30L × 50% = ₹15 lakh
  • Tax on ₹15L

Why 50% for profession?: Professionals have lower expenses (no inventory, raw materials)


Tax Audit Limits

Section 44AB: Compulsory tax audit if:

Business:

  • Turnover > ₹1 crore (in FY 2023-24, increased from ₹1 cr in certain cases)
  • OR voluntary opted out of presumptive (44AD) and income > ₹25L

Profession:

  • Gross receipts > ₹50 lakh
  • OR opted out of 44ADA and income > ₹25L

Audit: CA must certify accounts


Specified Professions (Section 44AA)

Must maintain books (no simplification):

  1. Legal
  2. Medical
  3. Engineering
  4. Architectural
  5. Accountancy
  6. Technical Consultancy
  7. Interior Decoration
  8. Authorized Representative (CA, CS, CMA)
  9. Film Artist
  10. Company Secretary

Other professions: Can use presumptive scheme


Mixed Activity

Both business and profession:

Example: CA firm

  • Profession: Audit, tax consulting
  • Business: Selling accounting software

Treatment: Calculate separately, combine for total PGBP income


Vocation

Section 2(36): Profession includes vocation

Vocation: Occupation not requiring formal qualification but skill/expertise

Examples:

  • Plumber (skilled, but no degree)
  • Carpenter
  • Electrician

Usually treated as: Business (for tax purposes, unless fall under specified)


"Adventure in the nature of trade"

One-time dealing with profit motive

Example:

  • Bought land to resell (not for use) → Business income, not capital gain!
  • Bought shares for quick profit (4-5 transactions/month) → Business income, not capital gain

Test: Intention at purchase - if intention was profit from resale → Business


Why Classification Matters?

Different treatment:

  1. Presumptive taxation: Business 8%, Profession 50%
  2. Audit limit: Business ₹1cr, Profession ₹50L
  3. Book-keeping: Profession stricter for specified
  4. TDS: Different sections may apply
  5. Expenses: Profession may have limited allowable expenses in some cases

Summary

  • Business: Trade, commerce, manufacture with profit motive - Shop, factory, trading (no qualification needed)
  • Profession: Specialized knowledge/skill requiring qualification - Doctor (MBBS), CA, Lawyer (degree mandatory)
  • Presumptive tax: Business 8% (Section 44AD), Profession 50% (Section 44ADA)
  • Audit limit: Business ₹1 crore turnover, Profession ₹50 lakh receipts
  • Key difference: Business can be transferred, profession is personal
  • Both taxed: Under same head (PGBP, Sections 28-44)
  • Classification matters: For presumptive tax, audit requirements, compliance

Quiz Time! 🎯

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