TaxTMI 
TaxTMI 
2000 (8) TMI 273
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....tor in respect of research and development section as under: ---------------------------------------------------- Building Rs. 2,18,582 Plant & Machinery Rs. 2,06,000 Tractor Rs. 1,37,474 ---------------------------------------------------- Total &....
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....ectly connected with the scientific research related to the business of assessee and consequently, it was held that assessee was entitled to 100% deduction in respect of these two items. However, in respect of expenditure on building, it was held by him that such expenditure was not directly connected with the scientific research. However, the assessee was held to be eligible for normal depreciation under section 32 on the specified block of assets. Aggrieved by the same, the assessee is in appeal before the Tribunal. 4. The Ld. counsel for the assessee, Shri Sathe has submitted before us that for claiming deduction under section 35, it is not necessary that expenditure must be directly connected with the scientific research. According t....
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....he rival submissions of the parties, we find force in the contention of the Ld. counsel for the assessee. No doubt, under section 35(1)(iv), the deduction is allowable in respect of expenditure of capital nature on scientific research which prima facie indicate that expenditure must be directly on scientific research. But, it appears from the scheme of the Act that Legislature has used the words "on scientific research" in the widest possible sense including the expenditure on immovable properties. The words "on scientific research" have been defined by the Legislature under section 43(4) according to which the expenditure incurred on scientific research would include all expenditure incurred for the prosecution, or the provision of facilit....