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The assessee received funds from DSIR, repayable as royalty equaling 1.3 times the amount, which the AO treated as royalty disallowing weighted deduction u/s 35(2AB). ITAT held the funds received were soft loans based on identical tripartite agreement terms in earlier years confirmed by Ministry of Science and Technology, unsecured loan treatment in financial statements, and interest disclosure and TDS on repayment. ITAT allowed weighted deduction u/s 35(2AB), directing AO to delete the disallowance.
The assessee received funds from DSIR, repayable as royalty equaling 1.3 times the amount, which the AO treated as royalty disallowing weighted deduction u/s 35(2AB). ITAT held the funds received were soft loans based on identical tripartite agreement terms in earlier years confirmed by Ministry of Science and Technology, unsecured loan treatment in financial statements, and interest disclosure and TDS on repayment. ITAT allowed weighted deduction u/s 35(2AB), directing AO to delete the disallowance.
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