2025 (3) TMI 1870

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....he issues urged in these appeals are identical in nature, they were heard together and are being disposed of by this common order for the sake of convenience. 2. The Grounds raised by the assessee for the AY.2018-19 reads as under: "Disallowance of weighted deduction amounting to INR 21,24,07,277 claimed under section 35(2AB) of the Act. 1. erred in disallowing the weighted deduction amounting to INR 21,24,07,277 claimed under section 35(2AB) of the Act, even though the Appellant has duly complied with all the conditions prescribed under section 35(2AB) of the Act and once the R&D facility is approved, entire expenditure incurred by the unit on scientific research is eligible for weighted deduction. 2. erred in....

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....pplier of high-volume critical controllers/ECUs having noval motor and engine control technologies, developed in-house. The assessee is operating in various business segments, namely, power generators, automotive, powered equipment etc. The assessee is the key supplier to various established automotive & off highway industry players, locally & globally. The assessee has developed motor controllers and genset controllers that do the job of real time engine management. As a result, the fuel consumption of the engines used in 2/3 wheelers and gensets reduces by 3 to 20%, depending on the engine variety and operating conditions. The assessee is in the field of innovation and is continuously developing technologies in the automobile sector and i....

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....SIR for these two years, in which case, there is failure to comply with all conditions prescribed for allowing deduction u/s 35(2AB) of the Act. Accordingly, we are of the view that the Ld.CIT(A) was justified in confirming the rejection of weighted deduction claimed by the assessee u/s. 35(2AB) of the Act. 6. We noticed earlier that the assessee has raised an alternative contention in Ground no.3 that the expenditure incurred by it on scientific research should be allowed under other provisions of the Act, viz., the capital expenditure incurred on scientific research should be allowed as deduction u/s. 35(1)(iv) of the Act and the revenue expenditure should have been allowed deduction either u/s. 37 or u/s 35(1)(i) of the Act, if the we....