https://www.taxtmi.com/caselaws?id=444697 The dominant issue was whether the PCIT validly assumed revisionary jurisdiction under s.263 to disallow deduction under s.35(2AB) for want of Form 3CL. The HC held that the assessee had produced auditor certification of eligible R&D expenditure during assessment, and Form 3CL was ultimately issued by the prescribed authority after the s.143(3) order and was also furnished by the assessee during the assessment proceedings; mere delay or non-communication by the authority could not render the assessment order erroneous. Consequently, the assessment allowing s.35(2AB) deduction was neither "erroneous" nor "prejudicial to the interests of revenue," and the s.263 revision was set aside; the revenue's challenge failed. en-us Tue, 10 Oct 2023 00:00:00 +0530 Thu, 19 Feb 2026 13:00:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=444697 The dominant issue was whether the PCIT validly assumed revisionary jurisdiction under s.263 to disallow deduction under s.35(2AB) for want of Form 3CL. The HC held that the assessee had produced auditor certification of eligible R&D expenditure during assessment, and Form 3CL was ultimately issued by the prescribed authority after the s.143(3) order and was also furnished by the assessee during the assessment proceedings; mere delay or non-communication by the authority could not render the assessment order erroneous. Consequently, the assessment allowing s.35(2AB) deduction was neither "erroneous" nor "prejudicial to the interests of revenue," and the s.263 revision was set aside; the revenue's challenge failed. Case-Laws Income Tax Tue, 10 Oct 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=444697