DEPUTY COMMISSIONER OF INCOME TAX, CHENNAI vs. MRF LIMITED, CHENNAI

ITA 54/CHNY/2025Status: DisposedITAT Chennai05 May 2025AY 2013-14Bench: SHRI ABY T. VARKEY (Judicial Member), SHRI JAGADISH (Accountant Member)1 pages
AI SummaryDismissed

What did the Tribunal hold?

The Tribunal held that the AO cannot sit in judgment over the report submitted by the prescribed authority (DSIR) in Form 3CL. The survey findings, being subsequent to the DSIR's approval, did not impact the validity of the deduction.

What were the facts?

The Revenue appealed against the CIT(A)'s order allowing deduction under Section 35(2AB) to the assessee. The Assessing Officer (AO) had disallowed the deduction based on a survey and a statement from an employee, questioning the nature of R&D activities.

What were the issues?

Whether the AO can disallow deduction under Section 35(2AB) based on survey findings when the DSIR has already approved the expenditure in Form 3CL.

Which sections of the Income-tax Act were involved?

Section 35(2AB),Section 133A

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Cases cited in this judgment(1)Show list

Detected automatically from the text. The count shows how many other judgments on BharatTax rely on the same authority.

  • 255 ITR 395
    255 ITR 395 · 2002 · HC
    3 citing

Income Tax Appellate Tribunal, ‘C’ BENCH: CHENNAI

Before: SHRI ABY T. VARKEY & SHRI JAGADISH

Hearing: 26.03.2025Pronounced: 05.05.2025

PER ABY T. VARKEY, JM: These are appeals preferred by the Revenue against the order of the Learned Commissioner of Income Tax (Appeals), (hereinafter referred

to as “the Ld.CIT(A)”), Chennai-20, both dated 28.10.2024 for the Assessment Years (hereinafter referred to as "AY”) 2013-14 & 2014-15

respectively. Both sides agreed that the issues permeating in both the appeals are identical and therefore, appeal for AY 2013-14 is taken as lead case, result of which will be followed for

The order continues below.

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