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“R&D expenditure”

Business ExpensesSection 35(2AB)Section 35(2AB)252 judgments

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

Leading authorities on R&D 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. Microlabs Ltd.
383 ITR 490 · 2016 · High Court
175
citing judgments

If an assessee possesses interest-free funds exceeding investments in tax-free securities, it is presumed that investments are made from these own funds, precluding disallowance of interest expenditure under Section 14A read with Rule 8D(2)(ii). Additionally, weighted deduction under Section 35(2AB) is computed on the gross expenditure incurred, not net expenditure after reducing income earned.

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.

PCIT v. Maruti Suzuki India Ltd.
397 ITR 681 · 2017 · High Court
84
citing judgments

For claiming weighted deduction under section 35(2AB), the existence of recognition for a Research and Development (R&D) Centre is relevant, not necessarily the date of approval or recognition.

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.

Judgments citing R&D expenditure

Asian Paints Limited, Mumbai vs. Dy. CIT Ltu, Mumbai

In the result, the appeal by the Revenue is partly allowed for statistical purposes

ITA 1673/MUM/2019[2015-16]Status: DisposedITAT Mumbai08 Mar 2024AY 2015-16

Bench: Shri Prashant Maharishi & Shri Sandeep Singh Karhail

For Appellant: Shri Fenil Bhatt a/wFor Respondent: Shri Vachashpati Tripathi
Section 10Section 142(1)Section 143(2)Section 143(3)Section 14ASection 250Section 37(1)

agree with the submissions of the assessee and restricted the weighted deduction on Asian Paints Ltd. ITA no.1673/Mum./2019 ITA no.2959/Mum./2019 R&D expenditure under section 35(2AB) of the Act on the basis of the certificate issued by the DSIR in Form No.3CL. 37. The learned ... no.2959/Mum./2019 certified by the prescribed authority whereas in the case of the assessee, the same is not certified to be eligible R & D expenditure to the extent of Rs.54.34 lakhs. 14. The le Counsel for the assessee has also relied on the decision of the Ahmedabad bench of ITAT

DCIT (Ltu) 2, Mumbai vs. Asian Paints Ltd, Mumbai

Appeal is dismissed

ITA 840/MUM/2018[2014-15]Status: DisposedITAT Mumbai06 Mar 2024AY 2014-15

Bench: Shri Prashant Maharishi & Shri Sandeep Singh Karhail

For Appellant: Shri Madhur AgrawalFor Respondent: Shri Vachashpati Tripathi
Section 10(34)Section 142(1)Section 143(2)Section 143(3)Section 144C(3)Section 14ASection 250

read with section 144C(3) of the Act did not agree with the submissions of the assessee and restricted the weighted deduction on R&D expenditure under section 35(2AB) of the Act on the basis of the certificate issued by the DSIR in Form No.3CL. 28. The learned ... D was duly certified by the prescribed authority whereas in the case of the assessee, the same is not certified to be eligible R & D expenditure to the extent of Rs.54.34 lakhs. 14. The le Counsel for the assessee has also relied on the decision of the Ahmedabad bench

Asian Paints Ltd, Mumbai vs. Asst CIT (Ltu) 2, Mumbai

The appeal is dismissed holding that the learned CIT appeal is correct in allowing

ITA 269/MUM/2018[2014-15]Status: DisposedITAT Mumbai06 Mar 2024AY 2014-15

Bench: Shri Prashant Maharishi & Shri Sandeep Singh Karhail

For Appellant: Shri Madhur AgrawalFor Respondent: Shri Vachashpati Tripathi
Section 10(34)Section 142(1)Section 143(2)Section 143(3)Section 144C(3)Section 14ASection 250

read with section 144C(3) of the Act did not agree with the submissions of the assessee and restricted the weighted deduction on R&D expenditure under section 35(2AB) of the Act on the basis of the certificate issued by the DSIR in Form No.3CL. 28. The learned ... D was duly certified by the prescribed authority whereas in the case of the assessee, the same is not certified to be eligible R & D expenditure to the extent of Rs.54.34 lakhs. 14. The le Counsel for the assessee has also relied on the decision of the Ahmedabad bench

DCIT (Ltu) 2, Mumbai vs. Asian Paints Ltd, Mumbai

Appeal is allowed

ITA 841/MUM/2018[2013-14]Status: DisposedITAT Mumbai05 Mar 2024AY 2013-14

Bench: Shri Prashant Maharishi & Shri Sandeep Singh Karhailasian Paints Ltd. Asian Paints House 6A, Shanti Nagar, Santacruz (East) Mumbai 400 055 Pan – Aaaca3622K Appellant Asstt. Commissioner Of Income Tax Large Taxpayer Unit-2, Mumbai V/S

For Appellant: Shri Madhur AgrawalFor Respondent: Shri Vachashpati Tripathi
Section 10(34)Section 142(1)Section 143(2)Section 143(3)Section 144C(3)Section 14ASection 250

IN THE INCOME TAX APPELLATE TRIBUNAL “K” BENCH, MUMBAI BEFORE SHRI PRASHANT MAHARISHI, ACCOUNTANT MEMBER AND SHRI SANDEEP SINGH KARHAIL

Asian Paints Ltd, Mumbai vs. Asst CIT (Ltu) 2, Mumbai

Appeal is allowed

ITA 268/MUM/2018[2013-14]Status: DisposedITAT Mumbai05 Mar 2024AY 2013-14

Bench: Shri Prashant Maharishi & Shri Sandeep Singh Karhailasian Paints Ltd. Asian Paints House

For Appellant: Shri Madhur AgrawalFor Respondent: Shri Vachashpati Tripathi
Section 10(34)Section 142(1)Section 143(2)Section 143(3)Section 144C(3)Section 14ASection 250

IN THE INCOME TAX APPELLATE TRIBUNAL “K” BENCH, MUMBAI BEFORE SHRI PRASHANT MAHARISHI, ACCOUNTANT MEMBER AND SHRI SANDEEP SINGH KARHAIL

Arrdy Enginnering Innovations (P) Ltd, Rourkela vs. The ACIT, Circle - 3(1), Visakhapatnam.

In the result, appeal of the assessee is allowed

ITA 432/VIZ/2012[2007-2008]Status: DisposedITAT Visakhapatnam28 Feb 2024AY 2007-2008

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Ble

For Appellant: Sri GVN Hari, ARFor Respondent: Dr. Aparna Villuri, Sr. AR
Section 143(3)Section 147Section 148Section 35Section 35(1)Section 35(1)(i)Section 35(1)(iv)Section 35(2)(ia)Section 40

cannot be allowed. 3. Even assuming (without admitting) that appellant was not eligible for weighted deduction U/s. 35(2AB) in respect of R&D expenditure towards field trials incurred at Rourkela (on the ground that the same was not covered under the definition of approved in-house R & D house ... litigation before the Hon’ble AP High Court), the Ld. AO was not justified in denying even the plain 100% deduction for R & D expenditure in respect of both revenue and capital expenditure as provided U/s. 35(1)(i) and (iv) read with section

Arrdy Engineering Innovatins (P) Ltd, Rourkela vs. The ACIT, Circle - 3(1), Visakhapatnam.

In the result, appeal of the assessee is allowed

ITA 431/VIZ/2012[2005-06]Status: DisposedITAT Visakhapatnam28 Feb 2024AY 2005-06

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Ble

For Appellant: Sri GVN Hari, ARFor Respondent: Dr. Aparna Villuri, Sr. AR
Section 143(3)Section 147Section 148Section 35Section 35(1)Section 35(1)(i)Section 35(1)(iv)Section 35(2)(ia)Section 40

cannot be allowed. 3. Even assuming (without admitting) that appellant was not eligible for weighted deduction U/s. 35(2AB) in respect of R&D expenditure towards field trials incurred at Rourkela (on the ground that the same was not covered under the definition of approved in-house R & D house ... litigation before the Hon’ble AP High Court), the Ld. AO was not justified in denying even the plain 100% deduction for R & D expenditure in respect of both revenue and capital expenditure as provided U/s. 35(1)(i) and (iv) read with section

Bharat Dynamics Limited, Hyderabad vs. DCIT., Circle-1(1), Hyderabad

Appeal of the assessee is allowed

ITA 472/HYD/2023[2018-19]Status: DisposedITAT Hyderabad20 Feb 2024AY 2018-19

Bench: Shri R.K. Panda & Shri Laliet Kumarassessment Year: 2018-19 Bharat Dynamics Limited, Vs. The Deputy Commissioner Hyderabad. Of Income Tax, Circle – 1(1), Pan : Aaacb7880N. Hyderabad. (Appellant) (Respondent) Assessee By: Shri Rajiv Dave, Ca. Revenue By: Ms. Helen Ruby Jesindha, Sr.Ar.

For Appellant: Shri Rajiv Dave, CAFor Respondent: Ms. Helen Ruby Jesindha
Section 143(3)Section 35Section 37Section 37(1)

lakhs. However, the assessee has been denied deduction on this sum u/s 37(1) of the Act itself also. We find that such R&D expenditure though not eligible for weighted deduction u/s 35(2AB) but is allowable as deduction u/s 37(1) of the Act to the extent

Bharat Electronics Limited, Bangalore vs. Assistant Commissioner of Income Tax, Large Payers Tax Unit, Circle-1, Bangalore

ITA 1067/BANG/2023[2018-19]Status: DisposedITAT Bangalore08 Feb 2024AY 2018-19

Bench: Shri George K. George & Shri Chandra Poojari

Section 10(34)Section 143(2)Section 14ASection 250Section 35Section 37

ITA No.1067/Bang/2023 Bharat Electronics Limited, Bangalore IN THE INCOME TAX APPELLATE TRIBUNAL “C” BENCH: BANGALORE BEFORE SHRI GEORGE K. GEORGE

Toyota Kirloskar Motor Private Limited, Bangalore vs. DCIT, Circle-7(1)(1), Bangalore

In the result, appeal of the assessee is partly allowed

ITA 863/BANG/2023[2018-19]Status: DisposedITAT Bangalore22 Jan 2024AY 2018-19

Bench: Shri George George K. & Shri Chandra Poojari

For Appellant: Shri Narendra Kumar Jain, A.RFor Respondent: Shri Senthil Kumar N., D.R
Section 40A(2)

IT(TP)A No.863/Bang/2023 M/s. Toyota Kirloskar Motor Pvt. Ltd., Bangalore IN THE INCOME TAX APPELLATE TRIBUNAL “B’’ BENCH: BANGALORE

Addl CIT RG 7(1), Mumbai vs. Piramal Enterprises Ltd (Formerly Knwon As Piramal Healthcare Ltd) (As Ultimate Successor to Nicholas Piramal India Ltd), Mumbai

ITA 5091/MUM/2010[2005-06]Status: DisposedITAT Mumbai11 Jan 2024AY 2005-06

Bench: Shri Kuldip Singh & Shri S Rifaur Rahmanassessment Year: 2005-06 M/S. Piramal Enterprises Dy. Commissioner Of Limited (Formerly Known Income Tax, As Piramal Healthcare Range-8(2)(1), Limited) (Earlier Known As Mumbai. Nicholas Piramal India Ltd.), Vs. Piramal Tower, Agastya Corporate Park, Lbs Marg, Kamani Junction, Kurla (West), Mumbai – 400 070 Pan: Aaacn4538P (Appellant) (Respondent) Assessment Year: 2005-06 Dy. Commissioner Of M/S. Piramal Enterprises Income Tax, Limited (Formerly Known Circle-8(2)(1), As Piramal Healthcare [Erstwhile Dcit Circle- Ltd.) (As Ultimate 7(1)], Successor To Nicholas Vs. Mumbai. Piramal India Ltd.), Piramal Tower, Ganpatrao Kadam Marg, Lower Parel, Mumbai – 400 013 Pan: Aaacn4538P (Appellant) (Respondent)

For Appellant: Shri Priyank Gala, A.RFor Respondent: Shri P.D. Chogule, (Addl. CIT) Sr. A.R
Section 28Section 40Section 45

before AO/before this office also. The said statutory Form No.3CM is a mandatory Form and as such, the AO has rightly held that R & D expenditure incurred at Ennore only after approval given by Ministry i.e. 23-2- 2005 can be allowed that too if given in Form No.3CM which ... record approval in prescribed form No.3CM before the AO as well as the Ld. CIT(A). It is fact on record that only R&D expenditure incurred at Ennore for which approval has been given by the Ministry on 29.03.2005 can be allowed only if form No.3CM is brought

Piramal Healthcare Ltd ( Earlier Knownas Nicholas Piramal India Ltd), Mumbai vs. Addl CIT 7(1), Mumbai

ITA 3706/MUM/2010[2005-06]Status: DisposedITAT Mumbai11 Jan 2024AY 2005-06

Bench: Shri Kuldip Singh & Shri S Rifaur Rahmanassessment Year: 2005-06 M/S. Piramal Enterprises Dy. Commissioner Of Limited (Formerly Known Income Tax, As Piramal Healthcare Range-8(2)(1), Limited) (Earlier Known As Mumbai. Nicholas Piramal India Ltd.), Vs. Piramal Tower, Agastya Corporate Park, Lbs Marg, Kamani Junction, Kurla (West), Mumbai – 400 070 Pan: Aaacn4538P (Appellant) (Respondent) Assessment Year: 2005-06 Dy. Commissioner Of M/S. Piramal Enterprises Income Tax, Limited (Formerly Known Circle-8(2)(1), As Piramal Healthcare [Erstwhile Dcit Circle- Ltd.) (As Ultimate 7(1)], Successor To Nicholas Vs. Mumbai. Piramal India Ltd.), Piramal Tower, Ganpatrao Kadam Marg, Lower Parel, Mumbai – 400 013 Pan: Aaacn4538P (Appellant) (Respondent)

For Appellant: Shri Priyank Gala, A.RFor Respondent: Shri P.D. Chogule, (Addl. CIT) Sr. A.R
Section 28Section 40Section 45

before AO/before this office also. The said statutory Form No.3CM is a mandatory Form and as such, the AO has rightly held that R & D expenditure incurred at Ennore only after approval given by Ministry i.e. 23-2- 2005 can be allowed that too if given in Form No.3CM which ... record approval in prescribed form No.3CM before the AO as well as the Ld. CIT(A). It is fact on record that only R&D expenditure incurred at Ennore for which approval has been given by the Ministry on 29.03.2005 can be allowed only if form No.3CM is brought

DCIT RG 8(2), Mumbai vs. Proctor & Gamble Hygiene & Health Care Ltd, Mumbai

In the result the appeals of the revenue are dismissed and the appeals of the assessee are partly allowed

ITA 2446/MUM/2013[2008-09]Status: DisposedITAT Mumbai12 Dec 2023AY 2008-09

Bench: Shri Aby T Varkey & Shri Amarjit Singhita No.3518 & 2277/Mum/2012 Procter & Gamble Hygiene Vs. Additional Cit Circle 8(2) & Healthcare Limited Mumbai -400020 P & G Plaza Cardinal Gracias Road, Chakkala, Andheri (East) Mumbai – 400009 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No:Aaacp6332M Appellant .. Respondent

For Appellant: Yogesh Thar, Ms. SukanyaFor Respondent: Tushar Mohite
Section 143(2)Section 143(3)

personnel which may be common expenses of the entire company which were already considered for allocation on the basis of turnover. Likewise the R&D expenditure and depreciation were already considered for allocation on the basis of the turnover ratio. The same principles apply even for the interest expenses allocation

Procter & Gamble Hygine & Health Care Ltd, Mumbai vs. Addl CIT Cir 8(2), Mumbai

In the result the appeals of the revenue are dismissed and the appeals of the assessee are partly allowed

ITA 1735/MUM/2013[2008-09]Status: DisposedITAT Mumbai12 Dec 2023AY 2008-09

Bench: Shri Aby T Varkey & Shri Amarjit Singhita No.3518 & 2277/Mum/2012 Procter & Gamble Hygiene Vs. Additional Cit Circle 8(2) & Healthcare Limited Mumbai -400020 P & G Plaza Cardinal Gracias Road, Chakkala, Andheri (East) Mumbai – 400009 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No:Aaacp6332M Appellant .. Respondent

For Appellant: Yogesh Thar, Ms. SukanyaFor Respondent: Tushar Mohite
Section 143(2)Section 143(3)

personnel which may be common expenses of the entire company which were already considered for allocation on the basis of turnover. Likewise the R&D expenditure and depreciation were already considered for allocation on the basis of the turnover ratio. The same principles apply even for the interest expenses allocation

Addl CIT RG 8(2), Mumbai vs. Proctor & Gamble Hyginene & Health Care Ltd, Mumbai

In the result the appeals of the revenue are dismissed and the appeals of the assessee are partly allowed

ITA 3566/MUM/2012[2007-08]Status: DisposedITAT Mumbai12 Dec 2023AY 2007-08

Bench: Shri Aby T Varkey & Shri Amarjit Singhita No.3518 & 2277/Mum/2012 Procter & Gamble Hygiene Vs. Additional Cit Circle 8(2) & Healthcare Limited Mumbai -400020 P & G Plaza Cardinal Gracias Road, Chakkala, Andheri (East) Mumbai – 400009 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No:Aaacp6332M Appellant .. Respondent

For Appellant: Yogesh Thar, Ms. SukanyaFor Respondent: Tushar Mohite
Section 143(2)Section 143(3)

personnel which may be common expenses of the entire company which were already considered for allocation on the basis of turnover. Likewise the R&D expenditure and depreciation were already considered for allocation on the basis of the turnover ratio. The same principles apply even for the interest expenses allocation

Procter & Gamble Hygiene & Health Care Ltd, Mumbai vs. Addl CIT Cir 8(2), Mumbai

In the result the appeals of the revenue are dismissed and the appeals of the assessee are partly allowed

ITA 3518/MUM/2012[2007-08]Status: DisposedITAT Mumbai12 Dec 2023AY 2007-08

Bench: Shri Aby T Varkey & Shri Amarjit Singhita No.3518 & 2277/Mum/2012 Procter & Gamble Hygiene Vs. Additional Cit Circle 8(2) & Healthcare Limited Mumbai -400020 P & G Plaza Cardinal Gracias Road, Chakkala, Andheri (East) Mumbai – 400009 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No:Aaacp6332M Appellant .. Respondent

For Appellant: Yogesh Thar, Ms. SukanyaFor Respondent: Tushar Mohite
Section 143(2)Section 143(3)

personnel which may be common expenses of the entire company which were already considered for allocation on the basis of turnover. Likewise the R&D expenditure and depreciation were already considered for allocation on the basis of the turnover ratio. The same principles apply even for the interest expenses allocation

Procter & Gamble Hygiene & Health Care Ltd., Mumbai vs. Addl.C.I.T. Cir. 8(2), Mumbai

In the result the appeals of the revenue are dismissed and the appeals of the assessee are partly allowed

ITA 2277/MUM/2012[2006-07]Status: DisposedITAT Mumbai12 Dec 2023AY 2006-07

Bench: Shri Aby T Varkey & Shri Amarjit Singhita No.3518 & 2277/Mum/2012 Procter & Gamble Hygiene Vs. Additional Cit Circle 8(2) & Healthcare Limited Mumbai -400020 P & G Plaza Cardinal Gracias Road, Chakkala, Andheri (East) Mumbai – 400009 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No:Aaacp6332M Appellant .. Respondent

For Appellant: Yogesh Thar, Ms. SukanyaFor Respondent: Tushar Mohite
Section 143(2)Section 143(3)

personnel which may be common expenses of the entire company which were already considered for allocation on the basis of turnover. Likewise the R&D expenditure and depreciation were already considered for allocation on the basis of the turnover ratio. The same principles apply even for the interest expenses allocation

Addl CIT RG 8(2), Mumbai vs. Proctor & Gamble Hygiene & Health Care Ltd, Mumbai

In the result the appeals of the revenue are dismissed and the appeals of the assessee are partly allowed

ITA 2167/MUM/2012[2006-07]Status: DisposedITAT Mumbai12 Dec 2023AY 2006-07

Bench: Shri Aby T Varkey & Shri Amarjit Singhita No.3518 & 2277/Mum/2012 Procter & Gamble Hygiene Vs. Additional Cit Circle 8(2) & Healthcare Limited Mumbai -400020 P & G Plaza Cardinal Gracias Road, Chakkala, Andheri (East) Mumbai – 400009 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No:Aaacp6332M Appellant .. Respondent

For Appellant: Yogesh Thar, Ms. SukanyaFor Respondent: Tushar Mohite
Section 143(2)Section 143(3)

personnel which may be common expenses of the entire company which were already considered for allocation on the basis of turnover. Likewise the R&D expenditure and depreciation were already considered for allocation on the basis of the turnover ratio. The same principles apply even for the interest expenses allocation

Deepak Novochem Technologies Ltd, Mumbai vs. The Assistant Commissioner of Income Tax, Central Circle-8(1), Mumbai

In the result, the appeals filed by the assessee are In the result, the appeals filed by the assessee are In the result, the appeals filed by the assessee are allowed partly for statistical purposes

ITA 2562/MUM/2023[2018-2019]Status: DisposedITAT Mumbai28 Nov 2023AY 2018-2019

Bench: Shri Om Prakash Kant () & Shri Rahul Chaudhary () Ita Nos. 2558 To 2562/Mum/2023 Assessment Years: 2014-15 To 2018-19 Deepak Novochem The Acit, Cc-8(1), Technologies Ltd., Aayakar Bhavan, Room No. Vs. 515, 5Th Floor, Citi Point, Boat 656, 6Th Floor, M.K. Road, Club Road, Pune City, Mumbai-400020. Pune-411 001. Pan No. Aaccd 5796 K Appellant Respondent Assessee By : Mr. H.P. Mahajani Revenue By : Mrs. Sanyogita Nagpal, Cit-Dr : Date Of Hearing 16/11/2023 Date Of Pronouncement : 28/11/2023

For Appellant: Mr. H.P. MahajaniFor Respondent: Mrs. Sanyogita Nagpal, CIT-DR
Section 35

been again highlighted in the bottom row of the Table as been again highlighted in the bottom row of the Table as-"Total R&D expenditure". Thus, the facts emanating from the documents submitted by the Thus, the facts emanating from the documents submitted by the Thus, the facts emanating ... PART consideration which clearly shows at Point 5(E) of PART consideration which clearly shows at Point 5(E) of PART-B-as "R&D Expenditure eligible for deduction u/s 35(2AB)" and NOT the TOTAL Expenditure eligible for deduction u/s 35(2AB)" and NOT the TOTAL Expenditure eligible

Deepak Novochem Technologies Ltd, Mumbai vs. The Assistant Commissioner of Income Tax, Central Circle-8(1), Mumbai

In the result, the appeals filed by the assessee are In the result, the appeals filed by the assessee are In the result, the appeals filed by the assessee are allowed partly for statistical purposes

ITA 2561/MUM/2023[2017-2018]Status: DisposedITAT Mumbai28 Nov 2023AY 2017-2018

Bench: Shri Om Prakash Kant () & Shri Rahul Chaudhary () Ita Nos. 2558 To 2562/Mum/2023 Assessment Years: 2014-15 To 2018-19 Deepak Novochem The Acit, Cc-8(1), Technologies Ltd., Aayakar Bhavan, Room No. Vs. 515, 5Th Floor, Citi Point, Boat 656, 6Th Floor, M.K. Road, Club Road, Pune City, Mumbai-400020. Pune-411 001. Pan No. Aaccd 5796 K Appellant Respondent Assessee By : Mr. H.P. Mahajani Revenue By : Mrs. Sanyogita Nagpal, Cit-Dr : Date Of Hearing 16/11/2023 Date Of Pronouncement : 28/11/2023

For Appellant: Mr. H.P. MahajaniFor Respondent: Mrs. Sanyogita Nagpal, CIT-DR
Section 35

been again highlighted in the bottom row of the Table as been again highlighted in the bottom row of the Table as-"Total R&D expenditure". Thus, the facts emanating from the documents submitted by the Thus, the facts emanating from the documents submitted by the Thus, the facts emanating ... PART consideration which clearly shows at Point 5(E) of PART consideration which clearly shows at Point 5(E) of PART-B-as "R&D Expenditure eligible for deduction u/s 35(2AB)" and NOT the TOTAL Expenditure eligible for deduction u/s 35(2AB)" and NOT the TOTAL Expenditure eligible