ACIT v. Intas Pharmaceuticals Ltd. (2025) 236 TTJ 550/ 174 taxmann.com 867 (Ahd)(Trib)

S. 35: Expenditure on scientific research-Allocation of common expenses to tax-exempt units-Eligible undertaking-Separate books and verifiable entries-Disallowance is not sustainable. [S.10AA, 80IC, 80IE]

 

Held that the assessee has maintained separate books of account for each unit, eligible for deduction under S. 10AA, 80-IC and 80-IE and the in-house R&D expenditure was incurred at a centralised R&D facility; the disallowance made by the AO by allocating a portion of common research and development expenses to the said tax-exempt units is not sustainable. (AY. 2015-16)

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