Tax & MSME · Provision

Section 43B(h), Income Tax Act — 45-Day MSME Payment Disallowance Rule (2026 Guide)

Section 43B(h), Income-tax Act, 1961

Unpaid dues to registered micro and small enterprises beyond 45/15 days are disallowed as business expenses and added back to taxable income.

Quick Statutory Answer

Under Section 43B(h) of the Income-tax Act, 1961 (inserted via Finance Act 2023), any payment owed to a registered Micro or Small enterprise beyond the statutory limit under Section 15 of the MSMED Act (maximum 45 days with written agreement, or 15 days without) cannot be claimed as a tax deduction on an accrual basis. If outstanding past the deadline at the end of the financial year (March 31), the entire expense is added back to taxable business income for that year and is deductible only in the year actually paid. Medium enterprises and traders are exempt.

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What the section does

  • Disallows income tax deductions for any sum payable to a registered micro or small enterprise if payment is not made within the time limit specified in Section 15 of the MSMED Act, 2006.
  • Where a written agreement exists, the statutory payment deadline is capped at 45 days from acceptance. Any contract clause providing for 60, 90, or 120 days is void under law.
  • Where no written agreement exists, payment is strictly due within 15 days of invoice or delivery.
  • Crucially, the proviso allowing deduction if paid before filing the Income Tax Return (due date under Section 139(1)) does NOT apply to clause (h). Deduction is allowed strictly in the previous year in which payment is actually discharged.
  • Applies only to suppliers registered as Micro or Small enterprises under Udyam. Medium enterprises and retail/wholesale traders are excluded from Section 43B(h) disallowance.

Section 43B(h) MSME Payment Deduction vs Disallowance Scenarios (AY 2024-25 & Beyond)

Section 43B(h) MSME Payment Deduction vs Disallowance Scenarios (AY 2024-25 & Beyond)
Supplier Category Agreement Terms Payment Date Income Tax Deduction Status MSMED Section 16 Penalty
Micro / Small Enterprise Written (e.g. 30 days) Paid within 30 days Allowed as deduction in current FY Nil
Micro / Small Enterprise Written (e.g. 60 days agreed) Paid on Day 42 (within 45 days) Allowed in current FY (statutory 45-day cap honoured) Nil
Micro / Small Enterprise Written (e.g. 60 days agreed) Paid on Day 50 (after 31 March) Disallowed in current FY; deductible in next FY when paid Compounded monthly at 3× RBI bank rate from Day 46
Micro / Small Enterprise No written agreement Paid on Day 20 (after 31 March) Disallowed in current FY (exceeded 15-day limit); deductible next FY Compounded monthly at 3× RBI bank rate from Day 16
Medium Enterprise Any terms Overdue at 31 March Allowed under standard mercantile accrual (Section 43B(h) exempt) Section 16 interest does not apply to medium units
Wholesale / Retail Trader Any terms Overdue at 31 March Allowed under standard mercantile accrual (Traders exempt under OM 2021) MSME Chapter V dispute resolution excluded

Tax consequence

100% deduction disallowed at 31 March. The overdue invoice amount is added back to taxable business profits for the financial year, triggering income tax liability plus MSMED Section 16 compound interest.

The deadlines

  • Day 0 — Goods delivered or services rendered by micro/small enterprise.
  • Day 15 — Payment due date if no written credit agreement exists between buyer and vendor.
  • Day 45 — Absolute statutory ceiling under Section 15 MSMED Act, even if contract stipulates longer terms.
  • March 31 — Balance sheet cut-off. If overdue and unpaid, the expense is disallowed under Section 43B(h) for the closing assessment year.
  • Date of Payment — Expense deduction is finally allowed in the subsequent financial year when payment is actually cleared.

Where people go wrong

  • Relying on payment before the ITR filing due date (Section 139(1)). The proviso allowing this explicitly excludes Section 43B(h). If overdue at March 31, it is disallowed for that fiscal year.
  • Agreeing to 60 or 90 days in purchase orders. Section 15 MSMED Act caps agreements at 45 days; clauses exceeding 45 days are legally void.
  • Failing to collect Udyam registration certificates from vendors to identify active Micro and Small suppliers before year-end audit.
  • Disallowing dues to Medium enterprises or Retail/Wholesale traders — CBDT guidelines clarify that 43B(h) is restricted strictly to Micro and Small manufacturing/service entities.
  • Forgetting that MSMED Section 16 penal compound interest is also permanently disallowed as an expense under Section 23 of the MSMED Act.

Common questions

Does Section 43B(h) apply if payment is made before filing the ITR?

No. The first proviso to Section 43B, which allows deductions for certain taxes and statutory liabilities paid before the ITR filing due date under Section 139(1), specifically excludes clause (h). If payment to a micro or small enterprise was overdue on March 31, the deduction is disallowed for that assessment year and can only be claimed in the subsequent year when actual payment is made.

Can a buyer agree to a 60-day credit period to avoid Section 43B(h) disallowance?

No. Section 15 of the MSMED Act mandates that the agreed period of credit cannot exceed 45 days. Even if both parties sign a contract for 60 or 90 days, the law caps it at 45 days. Any payment made after 45 days is overdue and triggers Section 43B(h) disallowance if unpaid by March 31.

Does Section 43B(h) apply to Medium enterprises or traders?

No. Section 43B(h) applies only to Micro and Small enterprises. Medium enterprises are excluded. Additionally, the Ministry of MSME circular (OM No. 5/2(2)/2021-E/P & G/Policy) clarified that registration of Retail and Wholesale Trade on Udyam is only for Priority Sector Lending and not for Chapter V benefits, exempting traders from 43B(h).

Is Section 16 MSME delayed payment interest tax-deductible?

No. Under Section 23 of the MSMED Act, 2006, any interest paid or payable by a buyer under Section 16 is explicitly non-deductible while computing taxable business income under the Income-tax Act, 1961.

What happens if the buyer disputes the invoice within 15 days?

Under the Explanation to Section 15 of the MSMED Act, if the buyer raises a written objection to the vendor within 15 days of delivery, the 45-day payment period commences only from the day the dispute is settled between the parties, postponing the 43B(h) disallowance trigger.

Act on this

  • Section 15 — the 45-day payment rule
  • Section 16 — interest on delayed payment
  • MSME interest calculator
  • MSME statutory notice template
  • What late payment to an MSME actually costs

About this summary

A plain-English summary of what this provision requires, not a reproduction of it and not legal advice. Read alongside the bare Act, and take advice on anything turning on your own facts.