9911796707
TMI Blog2023 (6) TMI 604X X X X Extracts X X X X X X X X Extracts X X X X ..... by the first appellate authority. As could be seen from the perusal of Form 3CL, it was issued by the competent authority on 31st March, 2022, which is post completion of assessment but before order was passed by the first appellate authority. Surprisingly, while deciding the appeal, the first appellate authority has completely ignored Form 3CL issued by the competent authority, though, it was ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... resent appeal is confined to disallowance of Rs. 29,05,724/- claimed as deduction under section 35(2AB) of the Income-tax Act, 1961 (in short the Act ). 3. Briefly the facts are, the assessee is a resident corporate entity engaged in manufacturing and sale of inks and toners for photocopiers. For the assessment year under dispute, the assessee filed its return of income claiming deduction unde ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... aring for the assessee submitted that, though, before the Assessing Officer, the assessee could not furnish Form 3CL, as, it was not issued by competent authority, however, in course of proceeding before the first appellate authority, the assessee did furnish Form 3CL issued by the competent authority for assessment years 2018-19, 2019-20 and 2020-21. He submitted, Form 3CL submitted by the assess ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nditure claimed as the Assessing Officer has allowed 100% deduction of revenue expenditure related to research and development. He has only disallowed the excess deduction claimed under section 35(2AB) of the Act. Pertinently, after completion of assessment the assessee did receive Form 3CL issued by the competent authority for assessment years 2018-19, 2019-20 and 2020-21, which was furnished bef ..... X X X X Extracts X X X X X X X X Extracts X X X X
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