(INDIA) — The Central Board of Direct Taxes (CBDT) released Draft Income-tax Rules, 2026 on February 19, 2026, including Draft Income Tax Rule 38, which sets out conditions for the CBDT to notify agricultural extension projects under section 47(1)(a) of the Income-tax Act, 2025.
Draft Income Tax Rule 38 links that notification process to deductions for expenditure on eligible projects, allowing taxpayers to claim deductions for related expenditures in the tax year of expenditure.
The draft framework centres on a CBDT notification as the trigger for eligibility under section 47, which covers deductions in the tax year of expenditure for notified agricultural extension or skill development projects.
Draft Rule 38 places the emphasis on what a project does, and on how a proposer demonstrates that work in a form the tax authority can evaluate. It describes agricultural extension activities in practical terms, such as farmer training, technology dissemination, or productivity enhancement, and ties those activities to alignment with national priorities.
A project seeking notification must promote agricultural extension activities rather than simply describing an agricultural objective in broad terms. The draft text highlights farmer-facing actions and measurable program goals as the core of what the CBDT will examine.
Applicants, under the draft rule, submit a detailed project proposal to the CBDT. The draft specifies that the proposal includes project scope and timelines, together with measurable outcomes such as beneficiary reach or yield improvements.
Financial detail is central to the application, with Draft Rule 38 calling for a budget with a breakdown that exceeds specified thresholds. The draft does not set out those thresholds in the summary description, but it frames the breakdown requirement as part of the information used to assess projects for notification.
Draft Rule 38 also makes the notification decision conditional on a verification process that goes beyond the project narrative. Approval requires checks on non-duplication with existing schemes, financial viability, and execution by eligible entities.
The draft describes eligible executing entities as including companies, cooperatives, or NGOs with agricultural expertise. That eligibility requirement functions as a gatekeeping condition, with the execution capacity and domain experience of the implementing body placed alongside project design and projected outcomes.
Non-duplication with existing schemes appears in the draft as a specific point for verification. The inclusion of this condition signals that the CBDT’s review focuses on whether the notified project stands apart from schemes already in place, rather than being a repackaging of ongoing work.
Financial viability is another stated verification requirement. The draft positions this as part of the approval test for notification, alongside the budget detail required from applicants and the project timeline and outcome measures.
Draft Rule 38 also sets a time-bound nature for notification status. Notified projects remain valid for a defined period, typically 3-5 years, and that continuing validity depends on periodic compliance reporting.
The draft’s reliance on periodic compliance reporting connects notification to ongoing oversight, rather than treating notification as a one-time administrative step. Applicants seeking a notification, and taxpayers relying on expenditure deductions tied to that status, must account for compliance reporting across the notified period.
The CBDT released the Draft Rules, 2026 alongside associated forms as accompanying materials to the Income-tax Act, 2025. The Act takes effect April 1, 2026.
The draft rules are open for stakeholder consultation. The CBDT framed that consultation as part of an effort to refine approval processes and reduce compliance burdens.
Within that broader draft package, Draft Income Tax Rule 38 lays out the procedural path for applicants in a way that ties form and substance together. A proposer prepares and submits the project proposal to the CBDT, ensuring it includes scope, budget elements with the required breakdown, timelines, and measurable outcomes.
Applicants also need to structure the project in a way that can pass the CBDT’s verification conditions. That means ensuring the executing entity fits the eligible categories and that the project does not duplicate existing schemes.
After submission, the draft contemplates a verification and approval process run by the CBDT to decide whether the project receives notification under section 47(1)(a). The draft links that notification to the ability to claim deductions for expenditure in the tax year of expenditure, which places timing and documentation of spend alongside the conditions for notification itself.
Draft Rule 38, as described in the draft rules package, therefore operates as a bridge between an activity-focused program in agriculture and the tax treatment of spending on that program. The notification is the mechanism that connects project design and implementation requirements to the deduction rule under section 47.
For entities considering proposals, the draft text implies a need to develop outcomes that the CBDT can assess. The examples listed for measurable outcomes—beneficiary reach and yield improvements—indicate the kind of evidence an applicant may need to plan for in advance when describing how extension activities will be delivered and how effects will be tracked.
The draft conditions also imply that the CBDT evaluates more than one dimension at once. Projects must meet an activity test by promoting agricultural extension aligned with national priorities, an information test by providing detailed scope, timeline, and outcome measures, and an administrative test through verification of non-duplication, viability, and eligible execution capacity.
The time-limited validity of notification, typically 3-5 years, means applicants design programs with a defined window in mind. Periodic compliance reporting, as described in the draft, becomes part of how notification status is maintained across that window.
The CBDT positioned the Draft Rules, 2026 as part of the implementation architecture for the Income-tax Act, 2025 ahead of April 1, 2026. In that context, Draft Income Tax Rule 38 functions as a rule-based description of how section 47(1)(a) operates for agricultural extension projects, with the CBDT notification standing as the formal instrument for project recognition.
The draft framework also directs readers to a more detailed reference point for precise criteria. For full details, the CBDT pointed stakeholders to the draft notification, indicating that projects must meet the criteria precisely for section 47(1)(a) eligibility.
Stakeholders assessing the draft now have two timelines to track inside the same package: the effective date of the Income-tax Act, 2025 on April 1, 2026, and the consultation period the CBDT opened to refine approval processes and reduce compliance burdens. The practical question for applicants becomes how to build proposals that meet the specified conditions while anticipating any refinements that emerge from consultation.
By specifying both the core content of the proposal and the CBDT’s verification requirements, Draft Income Tax Rule 38 sets a compliance-oriented template for agricultural extension projects seeking notification. The draft also frames notification not as an end point, but as a status maintained through periodic reporting during the validity period, typically 3-5 years, with deductions tied to eligible expenditure in the tax year of expenditure under section 47.
CBDT Notifies Draft Income Tax Rule 38 Under Section 47(1)(a)
India’s CBDT has introduced Draft Rule 38, outlining the procedures for agricultural extension projects to gain official notification. This status allows entities to deduct project expenses in the year they are incurred. The draft emphasizes measurable goals, financial transparency, and the use of eligible entities like NGOs or cooperatives. Notifications are time-bound, typically lasting 3-5 years, contingent upon periodic compliance reporting.
