SANZYME PRIVATE LIMITED,HYDERABAD vs. DCIT, CIRCLE-3(1), HYDERABAD

ITA 1847/HYD/2025Status: DisposedITAT Hyderabad18 September 2026AY 2018-1910 pages
AI SummaryPartly Allowed

What were the facts?

The assessee claimed weighted deduction under Section 35(2AB) for R&D expenditure. The Assessing Officer restricted the deduction based on DSIR approval, disallowing a portion. The CIT(A) upheld this.

What did the Tribunal hold?

The Tribunal held that clinical trial expenditure incurred outside the approved R&D facility is eligible for weighted deduction under Section 35(2AB). For other expenses, the matter was remanded for verification under Section 37(1).

What were the issues?

Whether clinical trial expenditure incurred outside the approved R&D facility is eligible for weighted deduction under Section 35(2AB), and if not, whether it is allowable as business expenditure under Section 37(1).

Which sections of the Income-tax Act were involved?

Section 35(2AB),Section 37(1),Section 143(3)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, Hyderabad ‘ B ‘ Bench, Hyderabad

Before: Shri Vijay Pal Rao, Vice-Shri Madhusudan Sawdia

Hearing: 02/09/2026

Per Madhusudan Sawdia, A.M.:

This appeal is filed by M/s. Sanzyme Private Ltd (“the assessee”), feeling aggrieved by the order passed by the Learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi (“Ld. CIT(A)”) dated 17.09.2025 for the A.Y.2018-19. 2. The assessee has raised the following grounds of appeal:

3.

The brief facts of the case are that the assessee is a private limited company engaged in the business of manufacture and sale of pharmaceutical formulations, nutraceuticals, health supplements, etc. The asses

The order continues below.

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