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Pre-commencement R&D deduction denied where business had not commenced; deeming benefit requires tangible start of manufacture or commercial exploitation.
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Deduction for capital expenditure on scientific research under section 35(1)(iv) is subject to the deeming rule only where the taxpayer has in fact commenced the business that will exploit the R&D; the deeming benefit for expenditure in the three years prior hinges on an ascertainable start of manufacture or commercial exploitation. The Tribunal held that absence of purchases, sales, closing stock, and only capital work in progress and unbilled dossier revenue showed no commencement; it allowed the Revenue's appeal, reversed the CIT(A) and upheld the AO's disallowance for AY 2018 19.
Deduction for capital expenditure on scientific research under section 35(1)(iv) is subject to the deeming rule only where the taxpayer has in fact commenced the business that will exploit the R&D; the deeming benefit for expenditure in the three years prior hinges on an ascertainable start of manufacture or commercial exploitation. The Tribunal held that absence of purchases, sales, closing stock, and only capital work in progress and unbilled dossier revenue showed no commencement; it allowed the Revenue's appeal, reversed the CIT(A) and upheld the AO's disallowance for AY 2018 19.
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