Next dueIncome Tax
7 NOVTDS / TCS deposit · Deducted in Oct 2026in 6 days 21 NOVITR filing · Audit cases · AY 2026-27 · extended from 31 Octin 20 days 15 DECAdvance Tax · 3rd (75%) instalment · FY 2026-27in 44 days 31 DECBelated / revised ITR · AY 2026-27in 60 days 30 SEPTax Audit Report · Form 3CA/3CB · AY 2027-28in 333 days 11 NOVGSTR-1 · Outward supplies · Oct 2026in 10 days 15 NOVPF & ESI · Contributions · Oct 2026in 14 days 20 NOVGSTR-3B · Summary return · Oct 2026in 19 days
All due dates

Rule 273 of Income-tax Rules 2026 — Film Distributor's Cost of Acquisition

Rule 273 of the Income-tax Rules, 2026 mirrors rule 272 for the film distributor, allowing the entire cost of acquisition in the year of acquisition where all rights are sold or...

Published
Updated
Reading time
8 min
Questions
8 answered
  • High Complexity
  • In-Depth Guide
Topic
Income Tax
Published
September 8, 2026
Last updated
Sep 8, 2026
Reading time
8 min
0:00
Last updated: September 2026Applies to: FY 2026-27 (AY 2027-28)Verified against: Government sources

The common structure

Rule 273 is drafted as a near-copy of rule 272, with cost of acquisition in place of cost of production and the film distributor in place of the film producer. The 1962 parallel is rule 9B. The three outcomes are identical in shape:

Situation in the year of acquisitionDeduction under rule 273Carry forward
Distributor sells all rights of exhibition — sub-rule (2)(a)Entire cost of acquisitionNone
Distributor exhibits himself, sells some areas, or both, and the film is released commercially at least ninety days before the year end — sub-rule (2)(b)Entire cost of acquisitionNone
Same activity, but not released ninety days before the year end — sub-rule (3)Capped at the amount realised by exhibition, the amount for which rights were sold, or the aggregateBalance to the next following tax year
Distributor neither exhibits nor sells — sub-rule (4)NilEntire cost to the next following tax year

Sub-rule (5) imposes the same crediting condition: the amounts realised, or the minimum guaranteed amount and any excess received or due — or, on the cash system, amounts received — must be credited in the books for the year in which the deduction is admissible.

The clock runs from acquisition, not certification

This is the first substantive difference and it is easy to miss because the wording is otherwise so close. Rule 272 measures everything from the year the film is certified for release by the Board of Film Censors. Rule 273 measures from the year the film is acquired by the film distributor. For a distributor who buys rights in a later year than certification — the ordinary case for a re-sale or a territory picked up after release — the relevant year, and therefore the ninety-day computation, is his own acquisition year.

The second difference — one delivery test, not two

Sub-rule (6)(b) of rule 273: the rights of exhibition are considered to have been sold only on the date when the positive prints of the film are delivered by the film distributor to the purchaser of such rights.

Rule 272(7)(b) has two limbs — delivery of positive prints, or, where the agreement provides that the distributor will make the prints, delivery of the negative. Rule 273 has only the first. A distributor who parts with a negative rather than prints has no equivalent provision fixing the date of sale, and must fall back on the general facts.

The third difference — the sub-distributor

Sub-rule (6)(c): "distributor shall include a sub-distributor". Rule 272 has no such provision, because it does not need one. In rule 273 the effect is to bring the whole chain within the rule: a sub-distributor acquiring territory rights from a distributor computes his deduction the same way, and the definition of cost of acquisition in sub-rule (6)(d) expressly contemplates an amount paid "to the film producer or to another distributor".

The fourth difference — no residual discretion

There is no equivalent of rule 272(6) in rule 273

Rule 272(6) lets the Assessing Officer allow a producer's deduction in such other manner as he considers suitable where the rights were transferred by a mode the rule does not cover, or where applying the rule is not practicable. Rule 273 contains no such provision. The consequence for a distributor with a modern licensing arrangement that maps onto neither "exhibits the film on a commercial basis" nor "sells the rights of exhibition" is that sub-rule (4) applies on its terms — no deduction that year, entire cost carried forward — with no discretionary route out. That asymmetry between two otherwise parallel rules is worth knowing before structuring a deal.

Cost of acquisition

Sub-rule (6)(d): "cost of acquisition" means the amount paid by the film distributor to the film producer or to another distributor under an agreement for acquiring the rights of exhibition — and where the rights were acquired on a minimum guarantee basis, the minimum amount guaranteed — not being:

  • expenditure incurred by the distributor on the preparation of positive prints; and
  • expenditure incurred by him in connection with the advertisement of the film.

Sub-rule (6)(a) adds that sale of rights includes their lease or transfer on a minimum guarantee basis.

The advertising exclusion is wider here than in rule 272

Rule 272(8)(b)(ii) excludes advertising expenditure incurred after the film is certified for release — so pre-certification publicity sits inside a producer's cost of production. Rule 273(6)(d)(ii) excludes advertising expenditure with no time qualifier at all. For a distributor, all advertising spend is outside cost of acquisition. That is not a disallowance — it remains ordinary deductible business expenditure — but it stays outside the deferral machinery of rule 273 and is therefore allowable in the year incurred.

Source note on the drafting

Two defects carried over from copying rule 272

First, sub-rule (1) of rule 273 reads: "In computing the profits and gains of the business of production of feature films carried on by a person (herein referred to as the film distributor)". Rule 272(1) uses the identical phrase for the producer. On its face rule 273 describes the wrong business — it should read distribution. Nothing else in the rule supports a production reading, and every operative sub-rule speaks of acquisition.

Second, sub-rule (5) joins its two cases with "and" — "(a) in a case where the film distributor ... and (b) in a case where the film distributor has transferred the rights on a minimum guarantee basis". Rule 272(5) uses "or". The two cases are mutually exclusive alternatives, so "and" cannot be read literally without making the condition impossible to satisfy.

Both are reproduced here rather than silently amended. Neither creates real doubt about the intended operation, but both are worth knowing before quoting the rule in a submission.

Worked example

FactsPosition under rule 273
Distributor acquires rights in July; sells all rights in SeptemberEntire cost of acquisition — no release test
Acquires in May; film released 1 November; year ends 31 MarchEntire cost — more than ninety days
Acquires in January; film released 10 MarchCapped; balance to the next year
Acquires in March; neither exhibits nor sells by year endNil; entire cost to the next year, with no discretionary relief
Film certified in an earlier year than acquisitionThe acquisition year governs
Sub-distributor acquires a territory from the distributorWithin the rule — sub-rule (6)(c)
Distributor delivers a negative rather than printsNo date-of-sale provision covers it, unlike rule 272
Minimum guarantee due but uncredited in the yearDeduction fails — sub-rule (5)
Distributor's print costsOutside cost of acquisition
Distributor's pre-release publicity spendOutside cost of acquisition — no time qualifier

Compliance checklist

  • Fix the tax year of acquisition — rule 273 runs from it, not from certification.
  • Establish whether all rights were on-sold, which removes the release test.
  • Count the ninety days back from the year end.
  • Where capped, quantify amounts realised and rights consideration and carry the balance forward one year.
  • Credit the corresponding receipts in the same year's books.
  • Date an on-sale by delivery of positive prints.
  • Treat a sub-distributor as within the rule.
  • Keep print and all advertising costs outside cost of acquisition, and remember there is no sub-rule (6) discretion to fall back on.

Common mistakes

  • Running the year from certification instead of acquisition.
  • Expecting an Assessing Officer discretion that rule 273 does not contain.
  • Importing rule 272's negative-delivery test into a distributor's computation.
  • Including advertising spend in cost of acquisition.
  • Overlooking a sub-distributor in the chain.
  • Failing to credit a minimum guarantee in the year of deduction.

Which year this governs

The Income-tax Rules, 2026 are made under the Income-tax Act, 2025. The 1962 parallel to rule 273 is rule 9B, given for tracing only. Verify the current text before finalising a distributor's computation.

Quick recapKey facts & short answers

Key Facts About Rule 273

  • Applies in: All states across India, under the relevant central law.
  • Mode: Mostly online via the official government portal.
  • Typical timeline: Ranges from a few days to a few weeks depending on the case.
  • Non-compliance: May attract penalties, interest or late fees.
  • Expert help: TaxClue completes the entire process end to end for you.

What does rule 273 allow?

A deduction for the cost of acquisition of a feature film certified for release by the Board of Film Censors, in computing the profits and gains of the film distributor.

When is the entire cost allowed?

Where, in the tax year of acquisition, the distributor sells all rights of exhibition; or exhibits the film himself or sells rights for some areas and the film is released for exhibition on a commercial basis at least ninety days before the end of that tax year.

If a rule seems to have changed, check the date of what you are reading before you act on it.

— TaxClue Compliance Desk

Rule 273: a key compliance topic in Indian tax and corporate law that businesses and individuals must understand to remain compliant.

Related Services & Guides

Was this article helpful?
About the author
Vikas Sharma Tax & Compliance Expert at TaxClue

Experienced in company registration, GST, trademark, and compliance. Helping Indian businesses stay compliant.

Updated:

Disclaimer: This article is for general informational purposes only and does not constitute professional tax, legal or financial advice. Laws, rates and due dates change and can vary by individual case — always verify with the relevant government source (e.g. mca.gov.in, incometax.gov.in) or consult a qualified professional before acting. TaxClue accepts no liability for decisions taken based on this content.

People also ask

Questions, answered

Short, direct answers to the 8 questions readers ask most on this topic.

A deduction for the cost of acquisition of a feature film certified for release by the Board of Film Censors, in computing the profits and gains of the film distributor.

Where, in the tax year of acquisition, the distributor sells all rights of exhibition; or exhibits the film himself or sells rights for some areas and the film is released for exhibition on a commercial basis at least ninety days before the end of that tax year.

The cost is allowed only up to the amount realised by exhibition, the amount for which rights were sold, or the aggregate, and the balance is carried forward to the next tax year.

No deduction that year; the entire cost of acquisition is carried forward to the next tax year and allowed there.

Yes. Rule 273(6)(c) provides that distributor shall include a sub-distributor.

Only on the date the positive prints are delivered by the film distributor to the purchaser of the rights.

The amount paid by the distributor to the producer or another distributor under an agreement for acquiring the rights of exhibition — and where acquired on a minimum guarantee basis, the minimum amount guaranteed — excluding expenditure on preparing positive prints and on advertising the film.

No. Rule 273 carries no equivalent of rule 272(6).