CEAT LIMITED,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX-6(1)(1)/ 6(2)(1), MUMBAI
What did the Tribunal hold?
The assessee sought to withdraw the appeal, stating that the reduction in the claim had no impact on its tax liability due to MAT provisions and that the disallowed expenditure was considered for normal deduction. The Tribunal allowed the withdrawal.
What were the facts?
The assessee, Ceat Limited, filed an appeal against an order related to a claim under Section 35(2AB) for scientific research expenditure. The Department of Scientific and Industrial Research (DSIR) had certified a lower amount of expenditure than claimed by the assessee.
What were the issues?
The primary issue was the reduction in the claim for scientific research expenditure under Section 35(2AB). The assessee's decision to withdraw the appeal was based on the lack of tax impact due to MAT provisions and alternative deductions.
Which sections of the Income-tax Act were involved?
Section 35(2AB),Section 115JB,Section 35(1)(i),Section 35(1)(iv)
AI-generated summary — verify with the full judgment below
Income Tax Appellate Tribunal, MUMBAI BENCHES, MUMBAI
Before: HON’BLE NARENDER KUMAR CHOUDHRY & HON’BLE ARUN KHODPIADr. A.B. Road, Worli, Mumbai,
आदेश / ORDER
PER: ARUN KHODPIA, ACCOUNTANT MEMBER: This appeal has been preferred by the Assessee against the order dated 25.11.2025, impugned herein, passed by the National Faceless Appeal Centre(NFAC)/Ld. Commissioner of Income Tax (Appeals) (in short Ld. Commissioner) u/s 250 of the Income Tax Act, 1961 (in short ‘the Act’) for the A.Y. 2017-18.
ITA No.863/MUM/2026 Ceat Limited
The Assessee has filed a letter dated 29.06.2026 seeking withdrawal of the present appeal. The contents thereof are reproduced herein below: -
“Sub: Appeal in the case of CEAT Limited v. DCIT, 6(1)(1), Mumbai being ITA No. 863/Mum/2026 for A.Y. 2017-18 fixed for hearing on July, 02, 2026. Re. : Withdrawal of appeal Kindly refer to the above appeal. In the Return of Income filed on 29.11.2017, we have made claim under section 35(2AB) of the Act. This claim was made in respect of scientific research expenditure being revenue expenditure of Rs. 46.70 cr. and capital expenditure of Rs. 60.95 cr. However, later on, the DSIR has (vide certificate in Form 3CL dated 29.11.2019) certified revenue expenditure of only Rs. 38.40 cr. and capital expenditure of Rs. 54.82 cr. No reasons have been cited by the DSIR. In light of the above, the A.O. has reduced the allowance u/s 35(2AB) proportionately. In the above appeal, this is the sole dispute. It has been realised that the above reduction in the claim has no impact on the tax liability of the current year as the income of the assessee is taxed under Minimum Alternate Tax ('MAT') provisions u/s 115JB of the Act. Further, since the assessee has switched over to new regime from A.Y. 2020-21 and substantial MAT credit has lapsed, there is no tax implications in subsequent years also. The assessee has also taken into account the fact that the scientific expenditure which is not allowed by the A.O. u/s 35(2AB), has been considered for normal deduction u/s 35(1)(i) and (iv) of the Act by the A.O. Considering all above, the assessee would like to withdraw aforesaid appeal for which leave may kindly be granted by the Hon'ble Bench. We humbly pray Your Honours to allow the withdrawal of the present appeal and dispose of the same accordingly.”
The Ld. D.R. raised no objection.
Thus, in view of the specific submissions {supra} and the prayer of the Assessee qua withdrawal of this appeal, the instant appeal is dismissed as withdrawn.
ITA No.863/MUM/2026 Ceat Limited
In the result, Assessee’s appeal is dismissed as withdrawn.
Order pronounced in the open court on 10.07.2026.
Sd/- Sd/- NARENDER KUMAR CHOUDHRY ARUN KHODPIA JUDICIAL MEMBER ACCOUNTANT MEMBER (Tarun Kushwaha) Sr. Private Secretary
Copy to: The Appellant The Respondent The CIT, Concerned, Mumbai The DR Concerned Bench
//True Copy// By Order
Dy/Asstt. Registrar, ITAT, Mumbai.
More judgments on Section 35(2AB)
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- Pochjraja Industries Ltd., Hosur vs ACIT, Circle-1, HosurITA 1072/CHNY/2025[2013-14]Status: Disposed23 Sept 2026AY 2013-14
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