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Renu Electronics Pvt. Ltd. vs. ACIT, Circle-5, Pune

Case No: ITA No.132/PUN/2024
Court: INCOME TAX APPELLATE TRIBUNAL, PUNE BENCH 'B', PUNE
Date: 9/20/2024

Parties Involved

appellantRenu Electronics Pvt. Ltd.
respondentACIT, Circle-5, Pune

Facts Summary

Renu Electronics Pvt. Ltd., a company engaged in the manufacture of electronic products, filed an appeal against the order of the Commissioner of Income Tax (Appeals) for the assessment year 2017-18. The assessee claimed a deduction under section 35(2AB) of the Income Tax Act for in-house research and development. The Assessing Officer disallowed the deduction as the assessee had filed Form 3CLA, required for claiming the deduction, after the due date. The Commissioner of Income Tax (Appeals) upheld the Assessing Officer's decision. The assessee argued that the delay in filing Form 3CLA was due to ignorance of a procedural change and that the Department of Scientific and Industrial Research (DSIR) had verified and approved the expenditure in Form 3CL. The Income Tax Appellate Tribunal set aside the order of the Commissioner of Income Tax (Appeals) and allowed the deduction as certified by DSIR in Form 3CL.

Decision in favour of

Assessee

Legal Issues

  • 1. Whether the Assessing Officer was justified in disallowing the deduction under section 35(2AB) due to the belated filing of Form 3CLA?

Judgment Outcome

Decided in favour of Assessee.

Precedents Relied Upon

14 precedents cited in this judgement.

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