ROTOFILT ENGINEERS LIMITED,AHMEDABAD vs. THE ACIT, CIRCLE-3(1)(1), AHMEDABAD

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ITA 1628/AHD/2025Status: DisposedITAT Ahmedabad11 February 2026AY 2012-13Bench: DR. BRR Kumar (Vice President), Shri T. R. Senthil Kumar (Judicial Member)12 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the Assessing Officer failed to conduct an independent examination after the matter was set aside. It further ruled that delays in approval do not affect eligibility for deduction under Section 35(2AB) and that the continuation of manufacturing does not negate R&D activities. The Tribunal also found no evidence of double deduction or failure to establish the nexus for R&D expenses.

What were the facts?

The assessee, an R&D recognized company, initially claimed deduction under Section 35(2AB) for R&D expenditure. During assessment, they withdrew this claim and sought depreciation. Later, they revised their claim for Section 35(2AB) deduction, which was disallowed by the AO and confirmed by the CIT(A).

What were the issues?

Whether the assessee is eligible for deduction under Section 35(2AB) for R&D expenditure despite procedural delays in approval and whether the AO properly adjudicated the claim after the matter was set aside.

Which sections of the Income-tax Act were involved?

Section 35(2AB),Section 80IB

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Income Tax Appellate Tribunal, AHMEDABAD “A” BENCH

Before: DR. BRR Kumar & Shri T. R. Senthil Kumar

आदेश क� ��त�ल�प अ�े�षत / Copy of Order Forwarded to:- 1. Assessee 2. Revenue 3. Concerned CIT 4. CIT (A)

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