Manugraph India Ltd. v. ACIT (Mum.)(Trib.) www.itatonline.org .

S. 37(1): Business expenditure – Scientific research expenditure – Expenditure not approved by DSIR for weighted deduction – Ordinary deduction allowable if expenditure incurred wholly and exclusively for business – Deduction allowed u/s 37(1).[ S. 35(2AB ) ]

 

The assessee claimed weighted deduction under section 35(2AB) in respect of expenditure incurred on in-house research and development. Part of the expenditure was not approved by the Department of Scientific and Industrial Research (DSIR), resulting in the denial of weighted deduction. The Tribunal held that although the expenditure was not eligible for weighted deduction under section 35(2AB), the revenue expenditure incurred for research and development purposes remained allowable as a normal business deduction under section 37(1). Following Auto Ignition Ltd. v. ADIT, ITA No.3248/Del/2017 dated 11.08.2021, and BEML Ltd. v. DCIT, ITA No. 291/Bang/2023, dated 19.07.2023, the Tribunal directed allowance of the unapproved R&D expenditure as revenue expenditure. ( AY. 2016-17 & 2017-18) (  ITA Nos. 7160 & 7161/Mum/2025, dt. 04-06-2026)

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