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2000 (8) TMI 273

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....ment section as under: ----------------------------------------------------      Building                     Rs. 2,18,582      Plant & Machinery            Rs. 2,06,000      Tractor                      Rs. 1,37,474 ----------------------------------------------------                  Total         &nb....

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....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 to him, it is sufficient if such expenditure is indirectly ....

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....ntention 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 facilities for the prosecution of scientific research. This definit....