Tribunal held  that from a reading of section 35(2AB), it was clear that once the research and development facility was approved by the Department of Scientific and Industrial Research, the expenses incurred by the assessee had to be allowed under section 35(2AB). If the law required the expenditure to be approved by the prescribed authority, that would have been expressly provided. In other words, for the purpose of section 35(2AB), it was provided that facility was to be approved and not the expenditure. Nowhere under the Act, was it stipulated that the deduction under section 35(2AB) was allowable only after approval by the Department of Scientific and Industrial Research. Rule 6(7A) of the Income-tax Rules, 1962 was amended by the Finance Act, 2016 with effect from July 1, 2016, wherein it provided that the prescribed authority had to quantify the expenditure incurred in the in-house research and development facility by the company. Prior to this amendment, no such power was vested with the Department of Scientific and Industrial Research. Since the present case related to a period prior to the amendment, deduction under section 35(2AB) had to be allowed on the basis of the expenditure as recorded by the assessee in the books of account. The amendment to rule 6(7A) was not procedural since the amended rule stipulated an additional condition and affected the substantive right of the assessee. Delay of filing of appeal due to Covid-  19 Pandemic  , was condoned .   ( AY.2016-17)