EDGEVERVE SYSTEMS LIMITED,BANGALORE vs. ACIT, CIRCLE-2(2)(1), BANGALORE

ITA 291/BANG/2025Status: DisposedITAT Bangalore30 January 2026AY 2018-1953 pages
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What did the Tribunal hold?

The Tribunal held that the approval of the R&D facility by DSIR and the genuineness of the expenditure were not disputed. The non-furnishing of Form 3CL during assessment and partial quantification by DSIR should not deny the weighted deduction, especially when the assessee also claimed alternative relief.

What were the facts?

The assessee claimed weighted deduction under Section 35(2AB) for in-house R&D expenditure. The Assessing Officer disallowed the weighted portion due to non-furnishing of Form 3CL during assessment, and the DSIR had only partially quantified the expenditure. Form 3CL was later produced in appeal, showing a portion of the expenditure was not quantified by DSIR.

What were the issues?

Whether weighted deduction under Section 35(2AB) is allowable on the entire R&D expenditure, including the portion not quantified by DSIR, and if not, whether it can be allowed under alternative sections.

Which sections of the Income-tax Act were involved?

Section 35(2AB),Section 35(1)(i),Section 37(1)

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Income Tax Appellate Tribunal, A BENCH, BANGALORE

Before: SHRI WASEEM AHMED & SHRI SOUNDARARAJAN K

For Appellant: Shri Padamchand Kincha, CA
For Respondent: Shri Shivanad Kalakeri, CIT (DR)
Hearing: 11.12.2025Pronounced: 30.01.2026

PER WASEEM AHMED, ACCOUNTANT MEMBER:

These five appeals filed at the instance of the assessee, are directed against the separate orders of the National Faceless Appeal Centre, Delhi (hereinafter the Ld. CIT(A)) passed under section 250 of the Income Tax Act, 1961 (hereinafter, the Act) for A.Ys. 2017-18 to 2021-22, which were heard together.

2.

First, we take up ITA No. 290/Bang/2025 pertaining to A.Y. 2017- 18 as the lead case. The assessee, in the memo of appeal, has raised four grounds bearing numbers as 1.1, 2.1 to 2.3, 3.1 to 3.4 and Ground No. 4. 3. The assessee vide application undated also raised an additional gro

The order continues below.

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