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“scientific research expenditure”

Business ExpensesSection 35Section 3555 judgments

The decision most relied on for scientific research expenditure is CIT v. Claris Lifesciences Ltd. (326 ITR 251), cited in 196 judgments on BharatTax.

Leading authorities on scientific research expenditure

CIT v. Claris Lifesciences Ltd.
326 ITR 251 · 2010 · High Court
196
citing judgments

If approval from the Department of Scientific and Industrial Research (DSIR) for an in-house R&D centre is granted during the previous year, the assessee is entitled to claim weighted deduction under section 35(2AB) for the entire expenditure incurred during that year.

CIT v. Sadan Vikas (India) Ltd.
335 ITR 117 · 2011 · High Court
112
citing judgments

Weighted deduction under Section 35(2AB) is allowable for R&D expenditure incurred even if the approval from the DSIR is granted in a subsequent assessment year, provided the application for approval was made in time. The assessee is entitled to the deduction if the approval is based on verification of details submitted.

Zandu Pharmaceuticals Works Ltd. v. CIT
350 ITR 366 · 2013 · High Court
68
citing judgments

Expenses, including scientific research or head office expenses, cannot be allocated to units eligible for deductions under sections 80IB or 80IC unless there is a clear nexus between the expenditure and the specific eligible unit for computing the deduction.

Cummins India Ltd. v. DCIT
96 Taxmann.com 576 · 2018 · ITAT
67
citing judgments

The weighted deduction for scientific research expenditure under Section 35(2AB) is allowable, clarifying that the requirement for the prescribed authority to approve or quantify the expenditure from year to year became effective only from April 1, 2016, through amendments to Rule 6(7A)(b).

CIT v. Cadila Healthcare Ltd.
31 Taxmann.com 300 · 2013 · High Court
65
citing judgments

Section 35(2AB), an incentive provision, allows weighted deduction for expenditure 'on in-house research or development facility' even if related activities like clinical trials are conducted externally, provided they are for the in-house research. This requires a liberal interpretation of the provision.

Sun Pharmaceutical Industries Ltd. v. Pr.CIT
162 ITD 484 · 2017 · ITAT
47
citing judgments

The approval of an in-house R&D centre through Form 3CM is the primary document for claiming weighted deduction under Section 35(2AB) for scientific research expenditure. The case clarifies the significance of this form and the role of the prescribed authority (DSIR) in the approval process.

Tejas Network Ltd. v. DCIT
60 Taxmann.com 309 · 2015 · High Court
41
citing judgments

The Assessing Officer cannot question the correctness of the certificate issued by the prescribed authority for claiming weighted deduction under section 35(2AB) for scientific research expenditure. The deduction is limited to the amount approved and certified by the competent authority.

Banco Products (India) Ltd. v. DCIT
95 Taxmann.com 132 · 2018 · High Court
36
citing judgments

A subsequent approval of Form 3CL does not invalidate a claim for deduction under Section 35(2AB) if the expenditure was otherwise approved. The deduction is available for expenditure incurred, even if the approval format was obtained later.

Judgments citing scientific research expenditure

Edgeverve Systems Limited, Bangalore vs. ACIT, Circle-2(2)(1), Bangalore

In the result, both the appeals of the assessee are partly allowed for statistical purposes

ITA 293/BANG/2025[2020-21]Status: DisposedITAT Bangalore30 Jan 2026AY 2020-21

Bench: Shri Waseem Ahmed & Shri Soundararajan K

For Appellant: Shri Padamchand Kincha, CAFor Respondent: Shri Shivanad Kalakeri, CIT (DR)
Section 250Section 254Section 37Section 90

quantified the entire expenditure. 53.5 Without prejudice, the learned AR submitted that even the expenditure not quantified by DSIR is otherwise allowable as scientific research expenditure under section 35(1)(i) of the Act, as it was incurred wholly and exclusively for the purposes of business. Alternatively, the same

Edgeverve Systems Limited, Bangalore vs. ACIT, Circle-2(2)(1), Bangalore

In the result, both the appeals of the assessee are partly allowed for statistical purposes

ITA 292/BANG/2025[2019-20]Status: DisposedITAT Bangalore30 Jan 2026AY 2019-20

Bench: Shri Waseem Ahmed & Shri Soundararajan K

For Appellant: Shri Padamchand Kincha, CAFor Respondent: Shri Shivanad Kalakeri, CIT (DR)
Section 250Section 254Section 37Section 90

quantified the entire expenditure. 53.5 Without prejudice, the learned AR submitted that even the expenditure not quantified by DSIR is otherwise allowable as scientific research expenditure under section 35(1)(i) of the Act, as it was incurred wholly and exclusively for the purposes of business. Alternatively, the same

Edgeverve Systems Limited, Bangalore vs. ACIT, Circle-2(2)(1), Bangalore

In the result, both the appeals of the assessee are partly allowed for statistical purposes

ITA 290/BANG/2025[2017-18]Status: DisposedITAT Bangalore30 Jan 2026AY 2017-18

Bench: Shri Waseem Ahmed & Shri Soundararajan K

For Appellant: Shri Padamchand Kincha, CAFor Respondent: Shri Shivanad Kalakeri, CIT (DR)
Section 250Section 254Section 37Section 90

quantified the entire expenditure. 53.5 Without prejudice, the learned AR submitted that even the expenditure not quantified by DSIR is otherwise allowable as scientific research expenditure under section 35(1)(i) of the Act, as it was incurred wholly and exclusively for the purposes of business. Alternatively, the same

Flamingo Pharmaceuticals Ltd, Sion Trombay Road Chembur vs. DCIT Circle-14(1)(2), Mumbai, Aaykar Bhavan, M.K. Road

In the result, the appeal of the assessee is allowed

ITA 4952/MUM/2025[2012-13]Status: DisposedITAT Mumbai17 Dec 2025AY 2012-13

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankar

For Appellant: Shri Ravindra Poojary,ARFor Respondent: Ms. Kavitha Kaushik, (Sr.DR)
Section 143(3)Section 35

score, by observing as follows: 6. Here it is seen that it is the assessee's stand that it had incurred in-house Scientific Research expenditure (capital and revenue). It had claimed weighted deduction u/s.35(2)(AB) of the Act, as under: i. Revenue expenditure of Rs.10 ... question. 8. It is seen that as rightly contended on behalf of the assessee, section 35 of the Act grants deduction for Scientific Research expenditure, under the circumstances prescribed there-under, on compliance of the conditions laid down in various provisions of section35. Now, whereas in some cases, like those

Deputy Commissioner of Income Tax Circle 8 1 (Incharge), Hyderabad vs. Virtusa Consulting Services Private Limited, Tamil Nadu

In the result, the ground of appeal in Ground No 2-4 in IT(TP)A No

ITA 2632/CHNY/2024[2013-14]Status: DisposedITAT Chennai14 Nov 2025AY 2013-14

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunathait (Tp) A No.:42/Chny/2024 & आयकर अपील सं./ Ita No.2262/Chny/2024 "नधा%रण वष% / Assessment Year: 2013-14 & 2012-13

For Appellant: Shri. N. V. Balaji, AdvocateFor Respondent: Shri. A R V Sreenivasan, C.I.T
Section 10ASection 35(1)(iv)

nature and hence dismissed. In the result, the appeal of the revenue in ITA No.2631/Chny/2024 is dismissed. 7. Issue No 2- Disallowance of Scientific research expenditure under section 35(1)(iv) 7.1 Moving on to Ground No.2 in ITA No.2632/Chny/2024, the same is in respect of deduction claimed

Assistant Commissioner of Income Tax, Hyderabad vs. Virtusa Consulting Services Private Limited, Chennai Tamil Nadu

In the result, the ground of appeal in Ground No 2-4 in IT(TP)A No

ITA 2631/CHNY/2024[2012-13]Status: DisposedITAT Chennai14 Nov 2025AY 2012-13

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunathait (Tp) A No.:42/Chny/2024 & आयकर अपील सं./ Ita No.2262/Chny/2024 "नधा%रण वष% / Assessment Year: 2013-14 & 2012-13

For Appellant: Shri. N. V. Balaji, AdvocateFor Respondent: Shri. A R V Sreenivasan, C.I.T
Section 10ASection 35(1)(iv)

nature and hence dismissed. In the result, the appeal of the revenue in ITA No.2631/Chny/2024 is dismissed. 7. Issue No 2- Disallowance of Scientific research expenditure under section 35(1)(iv) 7.1 Moving on to Ground No.2 in ITA No.2632/Chny/2024, the same is in respect of deduction claimed

Virtusa Consulting Services Pvt. Ltd., Chennai vs. DCIT, CC-5(2), Chennai

In the result, the ground of appeal in Ground No 2-4 in IT(TP)A No

ITA 2262/CHNY/2024[2012-13]Status: DisposedITAT Chennai14 Nov 2025AY 2012-13

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunathait (Tp) A No.:42/Chny/2024 & आयकर अपील सं./ Ita No.2262/Chny/2024 "नधा%रण वष% / Assessment Year: 2013-14 & 2012-13

For Appellant: Shri. N. V. Balaji, AdvocateFor Respondent: Shri. A R V Sreenivasan, C.I.T
Section 10ASection 35(1)(iv)

nature and hence dismissed. In the result, the appeal of the revenue in ITA No.2631/Chny/2024 is dismissed. 7. Issue No 2- Disallowance of Scientific research expenditure under section 35(1)(iv) 7.1 Moving on to Ground No.2 in ITA No.2632/Chny/2024, the same is in respect of deduction claimed

Pharmanza Herbal Private Limited, Dharmaj vs. The Principal Commissioner of Income Tax, Vadodara-1, Vaodara

ITA 749/AHD/2024[2018-19]Status: DisposedITAT Ahmedabad08 Oct 2025AY 2018-19

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Shri Biren Shah, ARFor Respondent: Shri Alpesh Parmar, CIT DR
Section 143(3)Section 263Section 35

Further, Form 3CL is one of the forms prescribed in Rule 6(7A)(b) of the Rules for quantifying scientific research expenditure by the Pharmanza Herbal Pvt. Ltd. vs. PCIT Asst.Year –2018-19 - 7– prescribed authority. Since the rules prescribe for examination of the above said form

Maruti Suzuki India Ltd., New Delhi vs. DCIT, New Delhi

In the result, all the three appeals of the assessee are allowed as indicated above and the appeal of Revenue is partly allowed

ITA 901/DEL/2017[2012-13]Status: DisposedITAT Delhi08 Oct 2025AY 2012-13

Bench: Shris.Rifaur Rahman & Shri Vimal Kumar

For Appellant: Shri Ajay Vohra, Sr. AdvocateFor Respondent: Shri G.C. Srivastava, Spl. Counsel for the Department
Section 143(3)Section 144CSection 144C(1)Section 144C(5)Section 14ASection 32Section 35Section 43B

assessee brought to our notice that the assessee had, during the year under consideration, claimed deduction in respect of scientific research expenditure incurred at its in-house facility in Gurgaon and Rohtak and the R&D facility at Rohtak was granted recognition / approval by DSIR in Form 3CM w.e.f ... allowed the deduction of the extent of Rs.249,52,70,000 claimed by the assessee in respect of scientific research expenditure incurred at Rohtak facility and accordingly, the impugned addition made in the final assessment order now stands reduced to Rs.5,00,000. The aforesaid amount of Rs.5

M/S Maruti Suzuki India Ltd., New Delhi vs. DCIT, New Delhi

In the result, all the three appeals of the assessee are allowed as indicated above and

ITA 287/DEL/2016[2011-12]Status: DisposedITAT Delhi08 Oct 2025AY 2011-12

Bench: Shris.Rifaur Rahman & Shri Vimal Kumar

For Appellant: Shri Ajay Vohra, Sr. AdvocateFor Respondent: Shri G.C. Srivastava, Spl. Counsel for the Department
Section 143(3)Section 144CSection 144C(1)Section 144C(5)Section 14ASection 35Section 43B

assessee brought to our notice that the assessee had, during the year under consideration, claimed deduction in respect of scientific research expenditure incurred at its in-house facility in Gurgaon and Rohtak and the R&D facility at Rohtak was granted recognition / approval by DSIR in Form 3CM w.e.f ... allowed the deduction of the extent of Rs.249,52,70,000 claimed by the assessee in respect of scientific research expenditure incurred at Rohtak facility and accordingly, the impugned addition made in the final assessment order now stands reduced to Rs.5,00,000. The aforesaid amount of Rs.5

DCIT, New Delhi vs. M/S. Maruti Suzuki India Ltd., New Delhi

In the result, all the three appeals of the assessee are allowed as indicated above and the appeal of Revenue is partly allowed

ITA 1024/DEL/2016[2011-12]Status: DisposedITAT Delhi08 Oct 2025AY 2011-12

Bench: Shris.Rifaur Rahman & Shri Vimal Kumar

For Appellant: Shri Ajay Vohra, Sr. AdvocateFor Respondent: Shri G.C. Srivastava, Spl. Counsel for the Department
Section 143(3)Section 144CSection 144C(1)Section 144C(5)Section 14ASection 32Section 35Section 43B

assessee brought to our notice that the assessee had, during the year under consideration, claimed deduction in respect of scientific research expenditure incurred at its in-house facility in Gurgaon and Rohtak and the R&D facility at Rohtak was granted recognition / approval by DSIR in Form 3CM w.e.f ... allowed the deduction of the extent of Rs.249,52,70,000 claimed by the assessee in respect of scientific research expenditure incurred at Rohtak facility and accordingly, the impugned addition made in the final assessment order now stands reduced to Rs.5,00,000. The aforesaid amount of Rs.5

ACIT, Ltu-2, Chennai vs. Ashok Leyland Limited, Chennai

In the result, appeal filed by the assessee is partly allowed and the appeal of the Revenue is dismissed

ITA 2618/CHNY/2019[2015-16]Status: DisposedITAT Chennai07 Jul 2025AY 2015-16

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

For Appellant: Mr.R. Vijayaraghavan, AdvFor Respondent: Mr.A. Sasikumar, CIT
Section 115JSection 143(3)Section 14A

facility under Section 35(2AB) of the Act. 6.1 The facts as discernible from records are that, the assessee had incurred scientific research expenditure, both revenue & capital, at their approved in-house house R&D facility. The assessee had accordingly claimed weighted deduction of Rs.397,38,59,287/- being

Ashok Leyland Limited, Chennai vs. ACIT, Chennai

ITA 2330/CHNY/2019[2015-16]Status: DisposedITAT Chennai07 Jul 2025AY 2015-16

Bench: Shri Aby T. Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita No.2330/Chny/2019 निर्धारण वर्ष/Assessment Year: 2015-16 M/S. Ashok Leyland Ltd., 1, Sardar Patel Road, Guindy, Chennai-600 032. [Pan: Aaaca 4651 L] (अपीलार्थी/Appellant) V. The Acit, Large Taxpayer Unit-2, Chennai. (प्रत्यर्थी/Respondent) आयकर अपील सं./Ita No.2618/Chny/2019 निर्धारण वर्ष/Assessment Year: 2015-16 The Acit, Large Taxpayer Unit-2, Chennai. V. M/S. Ashok Leyland Ltd., 1, Sardar Patel Road, Guindy, Chennai-600 032. [Pan: Aaaca 4651 L] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) Assessee By : Mr.R. Vijayaraghavan, Adv. & Mr.Vikram Vijayaraghavan, Adv. Department By : Mr.A. Sasikumar, Cit सुनवाईकीतारीख/Date Of Hearing : 02.05.2025 घोषणाकीतारीख /Date Of Pronouncement : 07.07.2025

For Appellant: Mr.R. Vijayaraghavan, AdvFor Respondent: Mr.A. Sasikumar, CIT
Section 115JSection 143(3)Section 14A

facility under Section 35(2AB) of the Act. 6.1 The facts as discernible from records are that, the assessee had incurred scientific research expenditure, both revenue & capital, at their approved in-house house R&D facility. The assessee had accordingly claimed weighted deduction of Rs.397,38,59,287/- being

Alp Overseas Pvt Ltd., New Delhi vs. ACIT Central Circle-20, New Delhi

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 2356/DEL/2023[2018-19]Status: DisposedITAT Delhi16 May 2025AY 2018-19

Bench: Shri Pradip Kumar Kedia & Shri Vimal Kumarassessment Year: 2018-19 Alp Overseas Pvt. Ltd., Vs. Acit, 25/3, Anbrose House, Central Circle -20, East Patel Nagar, New Delhi New Delhi Pin 1100 08 Pan No. Aaacg6366L (Appellant) (Respondent)

For Appellant: Shri Pranshu Goel, CA & Shri AdityaFor Respondent: Shri Amit Shukla, Sr. DR
Section 115JSection 142(1)Section 143(2)Section 143(3)Section 35Section 35(1)Section 37(1)

under s. 35(1) of the Act. 8 12. It is the contention of the assessee that the disallowance carried out towards house scientific research expenditure e- incurred by assessee is simultaneously eligible under Section 35(1) of the Act and therefore disallowance of Rs. 21,71,118/- requires

Crest Speciality Resins Private Limited, Kheda, Gujarat vs. Assistant Commissioner of Income Tax, Circle 1(1)(2), Ahmedabad (Now DCIT, Circle 1(1)(1), Ahmedabad), Gujarat

In the result, the appeal of the assessee is allowed for both the years under

ITA 1585/AHD/2024[2016-17]Status: DisposedITAT Ahmedabad15 May 2025AY 2016-17

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

For Appellant: Ms. Amrin Pathan, A.RFor Respondent: Shri B. P. Srivastava, Sr. D.R
Section 250Section 35Section 40A(2)(b)

decision is reproduced as under:- "6. Here it is seen that it is the assessee's stand that it had incurred in-house Scientific Research expenditure (capital and revenue). It had claimed weighted deduction u/s.35(2)(AB) of the Act, as under: i. Revenue expenditure of Rs.10 ... question. 8. It is seen that as rightly contended on behalf of the assessee, section 35 of the Act grants deduction for Scientific Research expenditure, under the circumstances prescribed there-under, on compliance of the conditions laid down in various provisions of section 35. Now, whereas in some cases, like

Crest Speciality Resins Private Limited, Kheda, Gujarat vs. Deputy Commissioner of Income Tax, Circle 1(1)(2), Ahmedabad (Now DCIT, Circle 1(1)(1), Ahmedabad), Gujarat

In the result, the appeal of the assessee is allowed for both the years under consideration

ITA 1583/AHD/2024[2015-16]Status: DisposedITAT Ahmedabad15 May 2025AY 2015-16

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

For Appellant: Ms. Amrin Pathan, A.RFor Respondent: Shri B. P. Srivastava, Sr. D.R
Section 250Section 35Section 40A(2)(b)

decision is reproduced as under:- “6. Here it is seen that it is the assessee’s stand that it had incurred in-house Scientific Research expenditure (capital and revenue). It had claimed weighted deduction u/s. 35(2)(AB) of the Act, as under: i. Revenue expenditure of Rs.10 ... question. 8. It is seen that as rightly contended on behalf of the assessee, section 35 of the Act grants deduction for Scientific Research expenditure, under the circumstances prescribed there-under, on compliance of the conditions laid down in various provisions of section 35. Now, whereas in some cases, like

Sedemac Mechatronics Limited, Mumbai vs. Assistant Commissioner of Income Tax Circle 15(3)(2), Mumbai

In the result, both the appeals filed by the assessee are treated as partly allowed

ITA 5484/MUM/2024[2018-19]Status: DisposedITAT Mumbai10 Mar 2025AY 2018-19

Bench: Justice (Retd.) Shri C.V. Bhadang & Shri B.R. Baskaran

For Appellant: Shri Pranay GandhiFor Respondent: Shri Alok Kumar, CIT-DR
Section 270ASection 35Section 35(1)(iv)Section 37

assessee claimed weighted deduction u/s. 35(2AB) of the Income Tax Act, 1961 (‘the Act’) in both the years in respect of scientific research expenditure incurred by it. However, the assessee could not furnish report in Form 3CL since the DSIR, Delhi did not issue the same for these

Sedemac Mechatronics Limited, Mumbai vs. Assistant Commissioner of Income Tax Circle 15(3)(2), Mumbai

In the result, both the appeals filed by the assessee are treated as partly allowed

ITA 5483/MUM/2024[2020-21]Status: DisposedITAT Mumbai10 Mar 2025AY 2020-21

Bench: Justice (Retd.) Shri C.V. Bhadang & Shri B.R. Baskaran

For Appellant: Shri Pranay GandhiFor Respondent: Shri Alok Kumar, CIT-DR
Section 270ASection 35Section 35(1)(iv)Section 37

assessee claimed weighted deduction u/s. 35(2AB) of the Income Tax Act, 1961 (‘the Act’) in both the years in respect of scientific research expenditure incurred by it. However, the assessee could not furnish report in Form 3CL since the DSIR, Delhi did not issue the same for these

Natco Pharma Limited, Hyderabad vs. ACIT., Circle-5(1), Hyderabad

In the result, appeal of the assessee is partly allowed for statistical purposes

ITA 853/HYD/2024[2020-21]Status: DisposedITAT Hyderabad19 Feb 2025AY 2020-21

Bench: Shri K. Narasimha Chary & Shri G. Manjunatha

For Appellant: Shri A V Raghuram, AdvocateFor Respondent: Shri B. Bala Krishna, CIT-DR
Section 143(2)Section 143(3)Section 144C(5)Section 35Section 41Section 80Section 92CSection 92D(3)

only on the basis of certificate issued by DSIR is incorrect. Thus, we direct the Assessing Officer to allow deduction towards actual scientific research expenditure incurred by the assessee in respect of revenue expenditure of Rs.15,79,54,772/- u/sec.35(1)(i) of the Act and restrict disallowance u/sec.35

Bajaj Holdings & Investment Ltd ( Formerly Bajaj Auto Ltd), Mumbai vs. ACIT Ltu, Mumbai

ITA 5299/MUM/2010[2006-07]Status: DisposedITAT Mumbai17 Feb 2025AY 2006-07
Section 143(3)

Notification No.245 of 2004 [S.O.1021(E)], dated 21/09/2004 reads as under: “SECTION 35(2AB)(1) OF THE INCOME-TAX ACT, 1961 - SCIENTIFIC RESEARCH EXPENDITURE - NOTIFIED ARTICLE OR THING FOR THE PURPOSE OF CLAUSE (1) OF SECTION 5(2AB)(1) NOTIFICATION NO. S.O. 1021(E), DATED 21-9-2004 In exercise