ZYDUS LIFESCIENCES LTD.,AHMEDABAD vs. THE DY.CIT, CENTRAL CIRCLE-2(1), AHMEDABAD

ITA 392/AHD/2023Status: DisposedITAT Ahmedabad29 January 2026AY 2017-18Bench: SMT. ANNAPURNA GUPTA (Accountant Member), Ms. SUCHITRA KAMBLE (Judicial Member)43 pages
AI SummaryPartly Allowed

What did the Tribunal hold?

The Tribunal upheld the authorities' decision to restrict weighted deduction for R&D expenses to the extent approved by the DSIR in Form 3CL. However, the AO was directed to consider the assessee's claim for deduction under sections 35(1)(i) & 35(1)(iv) as per the DRP's directions.

What were the facts?

The assessee company, Zydus Lifesciences Ltd., appealed against the order of the DCIT concerning assessment year 2017-18. The appeal involved issues related to transfer pricing adjustments, disallowance of weighted deduction for R&D expenses, and other tax credits.

What were the issues?

The key issues were the validity of the Transfer Pricing Officer's order beyond the time limit, the eligibility and extent of weighted deduction for R&D expenses, and the correct treatment of various tax credits and reliefs.

Which sections of the Income-tax Act were involved?

Section 92CA,Section 153,Section 144C,Section 143(3),Section 35(2AB),Section 35(1)(i),Section 35(1)(iv),Section 90,Section 270A,Section 271G

AI-generated summary — verify with the full judgment below

Cases cited in this judgment(3)Show list

Detected automatically from the text. Citations are also linked where they appear in the judgment. The count shows how many other judgments on BharatTax rely on the same authority.

Income Tax Appellate Tribunal, “D” BENCH, AHMEDABAD

Before: SMT. ANNAPURNA GUPTA & Ms. SUCHITRA KAMBLE

For Appellant: Shri Mukesh Patel, Shri Ajit Kumar, Ms. Sonal Pandey, ARs, Shri Prathvi Raj Meena, CIT.DR
For Respondent: Shri Prathvi Raj Meena, CIT.DR
Hearing: 31/10/2025Pronounced: 29/01/2026

PER ANNAPURNA GUPTA, AM:

The present appeal has been filed by the assessee against the order of the Ld. Dy. Commissioner of Income Tax, Ahmedabad (hereinafter referred to as “DCIT”), dated 30.03.2023 passed under Section 153C r.w.s. 144C r.w.s. 143(3) of the Income Tax Act,

ITA No. 392/Ahd/2023 [Zydus Lifesciences Ltd. vs. DCIT] A.Y. 2017-18 - 2 –

1961 (hereinafter referred to as the “Act”) and relates to

The order continues below.

Read the full judgment

A free account opens 10 full judgments a month. Re-reading one you have already opened does not count again.

Create a free accountSign in

See plans and prices

The summary, the parties, the sections and the citations above are open to everyone and always will be. Only the text of the order and the PDF are metered.

More judgments on Section 92CA

All 3,978 judgments and leading authorities on Section 92CA →

Recent GST High Court judgments

Search GST case law →