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2020 (8) TMI 240 - HC - Income TaxResearch and Development expenditure u/s 35(AB)(2) - weighted deduction at the rate of 200% - HELD THAT:- It is not in dispute that the appellant is having it's registered office at Chennai and manufacturing units at Hosur, Pune, Bangalore and Himachal Pradesh, for manufacture seats and parts of seats for automobile application. A perusal of Form 3CL dated 14.08.2015 appended to the typed set of documents, does not throw any light (or) supportive of the case of the appellant / assessee that the benefits of the research and development done by the Hosur unit having been availed by their manufacturing unit at Himachal Pradesh. In order to draw presumption that Himachal Pradesh unit does not have availed the benefit of the research and development done by the Hosur Unit, no material whatsoever has been placed by the appellant/assessee, before the assessing officer. It is not the case of the assessee that the unit at Himachal Pradesh is having it's own Research and Development Unit. Considered opinion of this Court is that the Assessing Officer as well as CTI (Appeals) and the ITAT, had thoroughly gone into the factual aspects and legal position and rightly arrived at the conclusion as to the plea made by the appellant. In sum and substance, the findings rendered by the authorities are concurrent in nature and therefore, there are no substantial questions of law arise for consideration in this appeal. - Appeal dismissed.
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